http://www.pacourts.us/OpPosting/Cwealth/out/2575CD09_9-1-10.pdf
This is an unreported case but the court gave a useful summary of the law on this issue:
This Court has held that abusive, vulgar, or offensive language addressed to a supervisor may support a finding of willful misconduct, so long as it is not provoked or de minimis.4 Allen v. UCBR, 638 A.2d 448, 451 (Pa. Cmwlth. 1994). Even a single instance of vulgarity directed to, and unprovoked by, a supervisor is sufficient for a finding of willful misconduct. Losch v. UCBR, 461 A.2d 344, 345 (Pa. Cmwlth. 1983). Furthermore, insubordination in general may constitute willful misconduct. Losch, 461 A.2d at 345.4 See, e.g., Blount v. UCBR, 466 A.2d 771 (Pa. Cmwlth. 1983) (holding that threat by claimant found to be off-hand utterance in nature of joke was not willful misconduct); Luketic v. UCBR, 386 A.2d 1045 (Pa. Cmwlth. 1974) (finding justified and not to be willful misconduct claimant’s statement that employer was being less than honest); Horace W. Longacre, Inc. v. UCBR, 316 A.2d 110 (Pa. Cmwlth. 1974) (holding allegedly offensive remark by claimant to be provoked and de minimis).
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