The case involved Ali Heidarshahi, a former employee of Clark County's Department of Juvenile Justice Services who was fired after a background check revealed he had misrepresented the circumstances of his departure from a previous job at a San Diego County juvenile detention center. The background check, required under the federal Prison Rape Elimination Act (PREA), uncovered that Heidarshahi had resigned in lieu of termination while under investigation for giving female residents his phone number and providing unnecessary items to detainees after being told to stop.
The Juvenile Justice Probation Officers Association sought to arbitrate the termination under their collective bargaining agreement, which allows arbitration of disputes over 'corrective actions' defined as measures 'implemented to assist an employee in overcoming a substantiated deficiency related to behavior or work performance.' However, Clark County argued the termination fell outside the agreement's scope because it was mandated by PREA regulations rather than progressive discipline. As Justice Stiglich wrote, 'corrective actions are narrowly defined as informal or formal actions implemented to assist an employee in overcoming a substantiated deficiency related to behavior or work performance.'
The court delivered its strongest language when distinguishing PREA-based terminations from traditional workplace discipline. 'Heidarshahi's termination was thus implemented pursuant to PREA regulations,' Justice Stiglich wrote. 'Whether or not this termination was justified under PREA, it nonetheless categorically falls outside of the scope of an action implemented to assist an employee in overcoming a substantiated deficiency related to behavior or work performance.'
The dispute arose after District Judge Jacob A. Reynolds of Clark County's Eighth Judicial District Court granted the county's motion to stay arbitration in the underlying case. The union had initiated grievance proceedings after Heidarshahi's 2026 termination, which was based on his failure to disclose disciplinary actions from his prior employment when he was hired by Clark County's juvenile justice department in 2016.
The union argued that all terminations listed in the CBA should be subject to arbitration, but the court rejected this broad interpretation. Justice Stiglich emphasized that the CBA's arbitration clause 'employs narrow and precise language' that 'limits arbitration to grievances regarding either interpretation and application of an express term of the CBA or disciplinary matters, defined within the CBA as corrective actions.' The court noted that while there is generally 'a strong presumption in favor of arbitration,' this presumption 'scales up or down, depending on the scope of the arbitration clause.'
The decision reinforces Nevada's recognition that PREA terminations serve a fundamentally different purpose than traditional progressive discipline. The court explained that PREA's mandate for 'zero tolerance toward all forms of sexual abuse and sexual harassment' in juvenile facilities creates termination grounds that are distinct from corrective actions designed to help employees improve their performance. PREA regulation 28 C.F.R. ยง 115.317(g) specifically provides that 'material omissions regarding such misconduct, or the provision of materially false information, shall be grounds for termination.'
Justice Stiglich, joined by Justices Parraguirre and Bell in the unanimous decision, declined to address whether Heidarshahi's termination was justified under PREA, noting that the court's 'review only addresses the arbitrability of Heidarshahi's termination and not whether Heidarshahi was properly terminated.' The ruling clarifies that Nevada courts will strictly construe narrow arbitration clauses in collective bargaining agreements, particularly when federal regulatory compliance is at stake.