MICHAEL A. CLEMONT
v.                  Docket No. 90-35-366
OHIO COUNTY BOARD OF EDUCATION

      D E C I S I O N

      Michael Clemont had been professionally employed by Re spondent Ohio County Board of Education (OCBE) for seventeen years prior to his dismissal effective August 14, 1990. On that date OCBE issued written charges against Grievant, reproduced here, in material part:
Pursuant to the provisions of [W.Va. Code §18A-2-8] [OCBE] hereby notifies you of your dismissal from its employment upon the grounds of immorality and incom petence. . . ..
Specific charges which support the basis of the conclusion that you have engaged in immoral conduct and have acted incompetently are as follows:
                   INCOMPETENCY
1.      Repeated failure to follow procedures in the establishment and maintenance of student records and files as documented by supervisors and evaluations.
2.      Repeated failure to maintain records of student transcripts as documented by supervisors, colleagues and clerical staff.
3.      Repeated incidents of losing and misplacing of student files as documented by supervisors, colleagues and clerical staff.4.      Repeated incidents of providing inaccurate advice concerning required subjects for graduation as docu mented by supervisors, colleagues and clerical staff.
5.      Repeated failure to post test scores to student records as documented by supervisors, colleagues and clerical staff.
6.      Inability to properly schedule and administer CTBS testing program, including written directions, disorganization and lack of required testing materi als.
7.      Repeated incidents of providing students incor rect information regarding college registration, time line and deadlines.
8.      Repeated incidents of not following procedures in the placement of students in the Bridges program housed at the YMCA.
9.      Repeated use of students for clerical tasks for student records maintenance in violation of confiden tiality provisions and specific directions to the contrary.
10.      Repeated removal of student records and files from the school premises despite specific directions to the contrary.
11.      Grossly inappropriate behavior at a neighboring state high school while purporting to represent Wheeling Park High School.
                   IMMORALITY
1.      Repeated incidents of uttering sexually explicit comments to female students.
2.      The sexual solicitation of a female high school student at a college party on September 30, 1989, during which you and underaged students consumed alcohol.
3.      Inappropriate touching of female students by having them sit on your lap in your office and at an after prom party from which you were told to leave.

Grievant filed a grievance directly to level four where hearing was held September 24 and 26, 1990. Grievant and OCBE filedsupportive briefs on December 14 and December 17, 1990, respec tively.
      OCBE's counsel opened the level four proceedings with the following statement, T. 7-9, in pertinent part:
[OCBE,] following a series of events which in. . .[its] opinion. . .reached proportions of which were of a nature that they no longer could be ignored, felt compelled to dismiss [Grievant] as a guidance coun selor. . .pursuant to [W.Va. Code §18A-2-8][.] [The grounds] were that [he] discharged his duties as a guidance counselor in an incompetent manner, and he was guilty of committing acts of immorality. . .. I think at the inception I should direct the hearing examiner's attention to the opinion of the West Virginia Supreme Court in Rovello v. Lewis County Bd. of Educ., 381 S.E.2d 237 [1989]. In the Rovello case the board of education of Lewis County attempted to dismiss a teacher on the grounds that he had misused school funds which was under §18A-2-8 considered an act of immorality. The teacher in that case raised a very interesting point that the board had to follow the mandates of Policy 5300 in terms of a plan of assistance, a period of improvement, that type of thing. That was not done in this case nor was it done in the Rovello case, and. . .[OCBE] takes the position on the strength of Rovello that if the only grounds for the dismissal were that [Grievant] acted in an incompetent manner the strong argument certainly could be made that he was entitled to a plan of assistance. However, I believe, as the testimony will develop here, [Grievant] was given, not necessarily a formal plan of assistance, but numerous opportunities to a) be aware of the areas of incompetence and b) a rea sonable opportunity to correct any of the deficien cies. However, beyond that we have three alleged acts of immorality, which, according to Rovello, and [OCBE] would urge here, cannot be corrected and are not subject to a plan of assistance and a reasonable opportunity to correct the deficiencies.

      Eleven witnesses appeared on OCBE's behalf: Wheeling Park High School (WPH) Principal George Krelis and Assistant Princi pals William Carman and Eric Carder; WPH's present guidance counselors, including Ronald DiLorenzo who had been named department chairman in August 1989, Dennis Regele, LelandSteiner and substitute Patricia Hershey, and a guidance depart mental clerk, Nancy Hartzell; OCBE member Mary Dolan; OCBE's Director of Student Services Dr. Bonnie Pollock; and a principal from a neighboring high school in the State of Ohio, Robert McNabb.   (See footnote 1)  Grievant testified on his own behalf, as did his father, Herbert Clemont, and his attending psychiatrist, Dr. David Hill.
      I.
      The facts in this case, gleaned from the parties' proposals and the total record, are basically presented in chronological order to most-clearly depict the sequence of events which led to Grievant's dismissal:
      1.      Grievant is certified in secondary math and guidance counseling. He had been assigned as a junior-high counselor since the 1974-75 school year. Beginning the 1986-87 academic year, he became one of the four guidance counselors at WPH.
      2.      Some primary functions of a WPH guidance counselor are to update and maintain various records, most of them of a sensitive nature, for approximately 370 students; to administer, record and interpret relevant testing; and to establish a rapport between his or her assignees in order to guide and to schedule them for classes which best meet their academic, vocational and personal needs. Student records should be handled in a manner so as to ensure confidentiality and must bestored, at all times, in the counselor's office, either on his or her desk or in a filing cabinet.
      3.      Grievant suffers from a mental illness known as bi- polar disorder, commonly referred to as manic-depressive psychosis. This malady can be controlled by the life-long administration of Lithium and, when needed for depression, the tranquilizer Haldol.
      4.      Grievant had been taking Lithium since 1974 when his mental illness was first diagnosed during a hospital stay. He was hospitalized again in 1980 during an acute stage of his illness, but had been stabilized with Lithium therapy until he voluntarily discontinued it in Fall 1988.
      5.      During the 1986-87 school year, specifically Spring 1987, Ms. Hartzell overheard Grievant ask a male student, who apparently attended a coed party and had hoped to encounter a certain female, the following: "Was she there? Did you make out?"
      6.      Grievant's evaluation for the 1986-87 school year reflected that he had been observed on an "on-going, monthly" basis, met all thirty-eight performance indicators and, overall, exceeded performance standards. Mr. Krelis, then an assistant principal, generally lauded Grievant's performance and only recommended that he "continue to learn intricacies of [WPH and its] guidance program" and to "pay stricter attention to cleri cal details needed to operate program effectively." The evalu ation contained no mention of the comment Grievant made to the male student which OCBE later alleged was an immoral act.      7.      During the 1987-88 school year Grievant was disorgan ized in October when he administered a student achievement test, and in Spring 1988 Grievant had not completed student informa tion on his guidance cards. Also in 1988, Mr. DiLorenzo ob served some of Grievant's students in his office using the telephone or doing clerical work while Grievant was not present and guidance cards were on his desk.
      8.      In February 1988, during a scheduling session for sophomore students in WPH's media center, a female student spoke out to Grievant, "What are you doing?" Grievant replied, "I'm playing with myself, what do you think." The session halted momentarily but then continued and was not otherwise disrupted. Mr. DiLorenzo, who had observed the incident, did not confront Grievant about it until he became the department head in 1989. At the time it occurred he had reported it to then-WPH head principal Phyllis Beneke, and he was "shocked" that Grievant had not come to him to apologize. T.126-128. In Spring 1988, Ms. Hartzell, who had been passing by Grievant's office, noticed through the wide-open door that a female student was seated on Grievant's knee.
      9.      On April 20, 1988, Grievant received his evaluation for the 1987-88 school year which again reflected that he had been observed on an "on-going" basis and had exceeded perfor mance standards, e.g., he met thirty-six out of thirty-nine indicators. Mr. Krelis noted that Grievant had "created an excellent rapport with students," but also recommended, however, that Grievant "learn more effective the totality of the operation of the Guidance Department. By learning and implementing facts more effective use of time will occur." He also counseled Grievant that "[w]hile it is admirable, even desirable to have students want to spend time with their counselor, too many students spend too much time in your office. I recommend strongly that you develop a system or structure that stops students from spending idle time in the office." The evaluation did not mention the comment Grievant made to the female student during sophomore scheduling in February 1988 or the incident of the female student sitting on Grievant's lap which OCBE later alleged were immoral acts.
      10.      In Fall during the 1988-89 school year, Grievant failed to keep records up to date, left guidance cards on his desk while he was not present and lost or misplaced files. In Spring 1989 Mr. Steiner found test booklets and completed answer sheets unattended in a room where he and Grievant had co- proctored a scholarship test. Mr. Steiner, who, in essence, conceded that Grievant may have been in the restroom, immediately placed the test data in a briefcase he thought to be Grievant's and returned it to the guidance office.
      11.      In Spring 1989 during an after-prom party, Grievant was observed relaxing in a lounge chair with his legs spread open; thereafter, a female student approached him and sat in the space on the seat between his legs. Students, parents, WPH staffers and OCBE member Mary Dolan were present on that occa sion.
      12.      There was conflicting testimony about the incident. Ms. Dolan related that, while she could not recall Grievant's attire, he had not stood up or otherwise disengaged himself and that the young lady remained on the chair conversing with him for approximately five minutes. Under cross-examination, T.103, Ms. Dolan said people were busy coming and going and she could not recall whether anyone besides her even noticed the incident.
      13.      Mr. Regele, who had also seen the event, testified that Grievant had changed from his formal attire and had been wearing tight "spandex" biking shorts. He said the student remained on Grievant's lap for about a minute.
      14.      Ms. Dolan had felt that Grievant's behavior was inappropriate, and she related her feelings about it to high- ranking OCBE administrators. She had first told OCBE's soon-to- depart Superintendent Henry Marockie and Assistant Superin tendent Frank Dumas. She then told OCBE's newly-appointed superintendent, Dr. Larry Jones, of the incident and that she did not approve of Grievant's behavior. However, there was no corroboration from any party that Grievant had been told to leave the after-prom party as was stated in OCBE's dismissal letter.
      15.      On May 9, 1989, Grievant received his evaluation for the 1988-89 school year. According to it, Grievant had been observed on an ongoing basis, attained twenty-four of thirty- eight indicators and met overall performance standards, well within the 18 to 32 point range. Mr. Krelis, who had become head principal in Fall 1988 following Ms. Beneke's untimely death, noted that improvement was needed in the following areas:(1)      A stronger organizational structure for delivery of services is needed. Organization by area, respon sibility, time-line, etc. need to be accomplished. Files need to be labeled for access, cumulative folders need appropriate daily filing, new entry data needs to be updated, and all confidential files should be out of view.
(2)      Student counseling must be kept at an academic level at all times. The office should be available at all times for students needing assistance, not a place to congregate.
(3)      Operation and involvement with Hi-Y must be directed as secondary to counseling responsibilities. Students should not be permitted at any time to use office as a place for leisure activity or meeting.
(4)      With 16 years experience as a teacher and coun selor and 3 years as a counselor at Wheeling Park High School, the many daily errors in operation must be eliminated. A proactive approach must be developed.

There was no mention of the after-prom party incident which OCBE later claimed was an immoral act on Grievant's part.
      16.      During the 1989-90 school year, Grievant had been disorganized in October 1989 when he had administered a test and had not fully cooperated with Mr. Regele in administering a scholarship; he also had not entered student test data into student files, and he had not maintained student transcripts.
      17.      Also in October 1989, Mr. Krelis and Mr. Carder confronted Grievant with a complaint from a student's father that Grievant had told his daughter words to the effect, "Come with me now or you'll be laid today." This incident occurred during a pre-game, college "block party" in Morgantown, West Virginia, a beer party separately attended by Grievant and the WPH student, who was visiting her sister, a college student. At a meeting concerning this event, Grievant did not explicitly deny that the statement was made, but said he had been joking.      18.      By letter dated October 20, 1989, Mr. Krelis presented Grievant the following findings and recommendation about the incident:
      First, I must emphasize that the alleged incident was formally presented to me by a student and her parent in concern for their [sic] daughter as it reflects upon her personal ability to deal with you as a counselor. With that in mind, both parent and student presented to me their concerns of what a professional educator projected to their [sic] daugh ter. Second, while you were indeed on you own per sonal time and actions during that time are your own, the image that you presented created questions in the minds of the student and parents. Third, the state ment allegedly made to the young lady, whether in tended as a humorous discussion or an inadvertent statement, brought a negative reaction from the young lady. Her parent brought the reaction to me and I to you. Finally, your presence at the party and your personal decision to drink while in attendance, while not projecting an acceptable image to the young lady or her parents, is a decision you personally must make.
      With all the information presented and the fact that you were not an official representative of [WPH] or the [school system], no recommendation regarding official action will be presented to the Superinten dent. However, I strongly urge you to introspectively view your role as a counselor, the image you project to our community in general, and, most importantly, to our students and their parents. Ultimately, you must determine how you can eliminate the concerns expressed and maintain your task assignment as Counselor at [WPH].

      19.      On November 1, 1989, Grievant visited a high school in a neighboring state and acted in a "bizarre" fashion. He had sought a student's files and initially had been angry, discour teous and demanding. However, after a time Grievant had sud denly become courteous and departed. Sometime shortly thereaf ter, Grievant was involuntarily hospitalized for his mental illness which was in an acute stage due to lack of Lithium.
      20.      After Grievant's hospitalization WPH's counselingstaff discovered that a number of Grievant's student files had been removed from the school premises. These files, possibly 100, were returned to the school by Grievant's father.
      21.      Ms. Hershey, the substitute guidance counselor who replaced Grievant at WPH, testified that she had numerous problems locating files and correcting Grievant's errors and omissions. Her difficulties with the files were not all reme died, even into the 1990-91 school year, according to her. However, Ms. Hershey admitted that she had never served as a guidance counselor before and that her only teaching experience, in another state, had been with elementary students.
      22.      When Grievant was able to resume work in January 1990, he was not returned to WPH but was assigned to instruct students in OCBE's new off-campus "Bridges" program. Bridges is a high- school program for students who are "at-risk" academically due to one or more factors, e.g., deficient intellectual abilities, substance abuse or family problems.
      23.      Dr. Pollock had been responsible for overseeing Grievant's work, but she had not conducted a formal observation of his Bridges classes. However, she once counseled Grievant about complaints she had heard about discipline in his classes, and the situation improved. Dr. Pollock also had to initially assist Grievant in preparing students' "modified educational plans," something of which he had had no previous experience, and he thereafter completed the plans.
      24.      On June 21, 1990, Mr. Carman issued Grievant's per formance evaluation for the 1989-90 school year. Mr. Carmannoted that Grievant had been observed "Ongoing 1st Semester." The evaluation reflected that Grievant had met only fifteen indicators and failed to meet overall performance standards. Mr. Carman added the following remarks to the evaluation:
      [Grievant] left [his counseling] position at the end of the first semester. His replacement found that the student records assigned to him were incomplete and in disarray. Several seniors were found to not be scheduled for the courses necessary for graduation. Mr. Clemont's performance as a counselor of high school students was unacceptable, and continuation at that level of placement is questionable.
      During his second semester placement [(Bridges)] the following concerns regarding and suggestions for improving Mr. Clemont's performance were noted:


No mention was made of Grievant's conduct at the Morgantown beer party which OCBE later claimed was an immoral act.
      25.      Mr. Carman conceded, T.113, that part of the reason Grievant did not meet counseling standards was because of the the time he, Grievant, was not on duty at WPH and was absent due to his illness and extended assignment with Bridges.
      26.      On August 1, 1990, Grievant and Mr. Carman signed a highly-detailed, six-page "Plan of Assistance" (Plan) which had been initiated and developed to assist Grievant with performing his duties as a counselor at WPH during the first semester of the 1990-91 school year. Mr. Carman admitted at hearing that the Plan had been prepared in anticipation of Grievant's continued employment as a guidance counselor at WPH, although he personally had not believed that Grievant should serve as a guidance counselor at the school.
      27.      The Plan covered every aspect of Grievant's profes sional performance. Despite no mention of Grievant's conduct in his formal evaluation, the Plan even included an instruction for him to engage in "appropriate role modeling" and to refrain from "illegal" and "immoral" conduct "which impacts upon his ability to perform the duties of a counselor which requires close personal relationships with students." Grievant was required to demonstrate, via various logs that he was to have kept and weekly meetings with administrators, that he had met the re quirements and objectives of the Plan.
      28.      According to the Plan, administrators would meet with Grievant during the first week of November 1990 "to discuss first quarter performance," and in late January 1991 to evaluate and determine whether a recommendation would be made "for dismissal" or to continue the plan for another semester. The Plan concluded on a positive note: "It is hoped that [Grievant] will be able to improve his performance to a level where the above stated deficiencies will no longer exist."
      29.      The record is silent about what events, if any, occurred between August 1 and August 14, 1990, the day OCBE dismissed Grievant.
      II.
      Among other things, Grievant argues that OCBE should reinstate him with full back pay because the dismissal action was "not based on just causes, but rather was arbitrary and capricious, was harsh, inappropriate, and unsupported by the facts of the case." Gr. Brief at 8-9. Grievant contends that the incidents cited by OCBE as examples of immorality do not reflect immoral conduct as defined by Golden v. Board of Educa tion, 285 S.E.2d 665 (W.Va. 1982). He claims that the remark which was made at the sophomore scheduling during the 1987-88 school year was only one incident of a sexually-explicit com ment, not "repeated incidents" as claimed in OCBE's written charges against him. He also notes that he received a favorable evaluation at the conclusion of that school year. He contends that nothing "untoward" happened when the female student sat on the chair with him in public at the Spring 1989 after-prom party and that the incident had not even caused a scene at the time. Grievant also maintains that OCBE did not conclusively prove that comments made by him to a female WPH student at a college beer party in Morgantown amounted to sexual solicitation of that student. He again points out that WPH's principal had already determined that official action was not warranted because the incident had occurred off-campus at a time when Grievant was not officially representing WPH.
      Grievant also argues that before OCBE can base a dismissal of him for behavior it considers immoral, it must show a "ra tional nexus" between the so-called immoral behavior and hisduties as a guidance counselor. OCBE rendered favorable evalu ations after all of the incidents in question; hence, Grievant argues, "there is no rational nexus between what [OCBE] has alleged is immoral conduct," Gr. Brief at 4, and his performance as a guidance counselor. In addition, Grievant argues that OCBE failed to establish a rational nexus in that it failed to show that his conduct "had become the subject of such notoriety as to significantly and reasonably impair his capability to discharge the responsibilities of a Guidance Counselor." Gr. Brief at 4. Thus, argues Grievant, OCBE has not established its charge of immorality and cannot dismiss him for this reason.
      Grievant likewise argues that OCBE cannot dismiss him for incompetency because it failed to provide him an improvement period as required by West Virginia Board of Education (BOE) Policy No. 5300(6)(a). Grievant notes that his only unfavorable evaluation occurred at the end of the 1989-90 school year, and during that year, he had only worked as a guidance counselor for two months, September and October 1989, at a time when his mental illness had reached a "crisis stage" requiring his hospitalization. He also urges that information on his 1989-90 evaluation about his performance in 1990 as a Bridges teacher was violative of Policy No. 5300(6)(a) since neither Mr. Carman nor Dr. Pollock formally evaluated his professional performance at Bridges. For these reasons, argues Grievant, OCBE wrongfully ignored Mr. Carman's Plan of Assistance and arbitrarily and capriciously dismissed him for incompetency.
      Finally, Grievant urges that his mental illness and manic-depressive psychosis affords him employee protections as a handicapped person under the "Human Rights Act Regulations." Grievant points out that he had lived with his illness for fifteen years and had been promoted from a junior high school to WPH during that period. Grievant claims that OCBE clearly is dissatisfied with him because of his illness but that it cannot terminate him on the basis of his handicap. Grievant contends that the wrongdoing about which OCBE complains, i.e., his failure to complete files, poor recordkeeping and uttering of sexual comments, were manifestations of his mental illness when he was not taking medication   (See footnote 2)  and his manic phase had reached crisis proportions. He argues that under Coffman v. Board of Regents, 386 S.E.2d 1 (W.Va. 1988), OCBE must reasonably accom modate him and that reasonable accommodation at this time would require it to afford him an opportunity to become regulated on his medicine so that he could continue his function as a guid ance counselor.   (See footnote 3) 
      In its post-hearing brief OCBE maintains that Grievant "forfeited his right and privilege" to be a guidance counselorin its schools and that it properly dismissed him as an employee for just cause. It contends that Grievant committed five distinct immoral acts, three while he was taking Lithium and two after he had voluntarily withdrawn from his therapy. It claims that the acts are significant, not only because of their common theme of "sexual provocation and promiscuity," but also because Grievant never denied committing any of them.   (See footnote 4) 
      OCBE claims the five acts of immorality alone warrant dismissal.   (See footnote 5)  It argues that it cannot reasonably accommodate Grievant, whose very job creates strong bonds with vulnerable and impressionable youth, by endorsing a counselor "who encour ages sexual promiscuity," and that it should not be compelled to place students in jeopardy by being exposed to Grievant's behavioral problems. In its fact/law proposals, OCBE also argues that, although Grievant had been dismissed for incompe tency and immorality, the record clearly established that he, in fact, was guilty of willful neglect of duty. In that vein OCBE argued that the record reflects a series of "abject abandonment" by Grievant of his duties as a steward of his students' records. It continues that
This entire record contains undisputed evidence of repeated failure to follow procedure in the mainte nance of student files and records; of inaccurate and often dangerously misleading advice concerning gradu ation requirements; of using students to perform tasks which reveal confidential information, and the in ability to administer various testing programs as signed to his care.

OCBE Brief at 11.
                   III.
      It is well-settled that the authority of a board of educa tion to dismiss a teacher under W.Va. Code §18A-2-8 "'must be based upon the just causes listed therein and must be exercised reasonably, not arbitrarily or capriciously.' Syllabus point 3, Beverlin v. Board of Education of Lewis County, 158 W.Va. 1067, 216 S.E.2d 554 (1975)." Syllabus, Rovello v. Lewis County Bd. of Educ., 381 S.E.2d 237 (W.Va. 1989). Additionally, a board of education bears the burden of proof that its dismissal action was justified. After a thorough consideration of the record and the parties' level four presentations and post-hearing propos als, the undersigned concludes that OCBE failed to establish cause or to justify its dismissal of Grievant.

      For one, OCBE's charge of immorality is not borne out by the record. In Golden at 668, the Court apparently adopted the definition of immorality as "conduct 'not in conformity with accepted principles of right and wrong behavior, which is contrary to the moral code of the community, which is wicked, and which, especially, is not in conformity with acceptablestandards of proper sexual behavior.'" The undersigned finds it difficult to view the immorality charges seriously since OCBE and its administrators obviously did not when the complained-of incidents occurred.
      For example, if WPH's administration believed Grievant's remarks to the male student were improper, it had a duty to inform him of such at the time. Ms. Beneke had apparently considered the sophomore-scheduling incident, duly reported to her by Mr. DiLorenzo, as being insignificant because it was not documented or otherwise even officially brought to Grievant's attention as to the propriety of his comment. In addition, the two incidents of Grievant's permitting a female student to sit on his lap are, without doubt, indicative of poor judgment on his part. However, the occurrences were widely-separated in time and, as such, do not give rise to even a hint that Grievant made a practice of such things. Further, OCBE presented no evidence that Grievant's conduct on those two occasions was in any way provocative, lewd or lecherous or that he engaged in any improper touching or sexually-suggestive behavior. Moreover, there was no testimony that Grievant overtly or covertly initi ated, encouraged or prolonged the contact; rather, it appears that he simply failed to terminate it. These events also were not documented or officially brought to Grievant's attention as examples of misconduct on his part at the time they occurred.
      Finally, while the Morgantown incident was another example of inappropriate behavior on Grievant's part, whether his conduct on that occasion could be labeled immoral or whether itbears on his occupational responsibilities   (See footnote 6)  is highly question able. Although OCBE may have had cause to discipline Grievant in October or November 1989 about his behavior at the beer party with the WPH student, OCBE apparently did not regard the conduct immoral at that time because its administrators advised Grievant that no disciplinary action would be taken on the complaint voiced by the student's father. Hence, OCBE's administrators dismissed the incident when it occurred and completely ignored it on Grievant's 1989-90 evaluation which covered the time-frame in question. For OCBE to resurrect this specific incident and indeed all of the other past but now complained-of incidents, as examples of conduct for which to base a dismissal on grounds of immorality, is capricious and unreasonable.
      Moreover, OCBE's post-hearing argument, see OCBE's Brief at 9, that Grievant's "performance as a guidance counselor consti tuted willful neglect of duty" must also be rejected. OCBE states that "there can be no serious challenge" to its "proof" of Grievant's willful neglect of duty. However, under the circumstances of OCBE's late-breaking reversal of its stated charge against him, Grievant did not have an opportunity to challenge that specific allegation. Irrespective of this, in the final analysis, the record does not support a determinationthat Grievant willfully neglected his duties. Tellingly, OCBE did not even attempt to define willful neglect of duty.
      In the 1990 West Virginia Supreme Court of Appeals case of Chaddock v. Board of Educ., 398 S.E.2d 120, 122, the Court noted that it had not previously defined willful neglect of duty, but then cited its statement in Fox v. Board of Educ., 260 S.E.2d 243 (1977), that the "term 'willful' ordinarily imports a knowing and intentional act, as distinguished from a negligent act." Obviously, given Grievant's mental ailment, his subpar counseling performance during the initial part of the 1989-90 school year cannot be attributed to intentional acts per Chaddock and Fox. The proper "label" for Grievant's shortcom ings as a counselor in the early months of the 1989-90 school year, as determined by WPH's trained administrator via a proper evaluation instrument, is incompetence.
      In a case such as this, the difference between specific charges of incompetency and willful neglect of duty, two dis tinct types of conduct, as bases for discharge have far-reaching consequences:
Failure by any board of education to follow the evaluation procedure in West Virginia Board of Educa tion Policy No. 5300(6)(a) prohibits such board from discharging, demoting or transferring an employee for reasons having to do with prior misconduct or incom petency that has not been called to the attention of the employee through evaluation and which is correct able.

Syl. pt. 3, Trimboli v. Board of Educ., 254 S.E.2d 561 (W.Va. 1979).   (See footnote 7)  As Grievant correctly argued, Policy No. 5300(6)(a)requires that an employee who does not meet standards must be afforded an improvement period, while such is not required for uncorrectable conduct amounting to willful neglect of duty.
      Despite some testimony elicited from WPH's present coun seling staffers about their perceptions of Grievant's shortcom ings over the years, the evaluations rendered by OCBE's school officials are the best evidence that Grievant had no significant performance problems until the 1988-89 school year. In fact, Mr. Krelis testified that Grievant had performed very well for a beginning counselor at WPH. Even after the 1988-89 school year, according to Grievant's evaluation rendered in Spring 1989, he still met overall performance standards, well within the nine teen to thirty-two point spread, and was not issued a formal plan of assistance or given time lines for remediation in areas deemed deficient.   (See footnote 8)  In short, the undersigned finds it extremely difficult to determine just why OCBE decided to terminate Grievant instead of permitting him an opportunity to improve per the Plan formulated for the 1990-91 school year; this record simply does not justify the dismissal action in August 1990.
      Notwithstanding the fact that Grievant will prevail in thismatter to the extent that he must reinstated and provided an improvement period, his request for reinstatement in light of his mental handicap is also persuasive. In Coffman the Court held that "under the West Virginia Human Rights Act and the accompanying regulations, 'reasonable accommodation' requires only that an employer make reasonable modifications or adjust ments designed as attempts to enable a handicapped employee to remain in the position for which he was hired." Id at 6. In this case, Grievant's request for reasonable accommodation is quite simple: He does not ask for light duty, less responsi bility or any physical alteration of his workplace; rather, he asks only for the opportunity to resume his position under the Plan, prepared in anticipation of his continued employment, albeit a trial period, now that his condition has been stabi lized by therapy.
      The factual and legal determinations contained in the foregoing discussion and analysis are incorporated in and made a part of the following formal conclusions of law.
      Conclusions of Law
      1.      "'The authority of a board of education to dismiss a teacher under. . .[W.Va. Code §18A-2-8] must be based upon the just causes listed therein and must be exercised reasonably, not arbitrarily or capriciously.' Syllabus point 3, Beverlin v. Board of Education of Lewis County, 158 W.Va. 1067, 216 S.E.2d 554 (1975)." Syllabus, Rovello v. Lewis County Bd. of Educ., 381 S.E.2d 237 (W.Va. 1989).
      2.      Failure by any board of education to follow theevaluation procedure in West Virginia Board of Education Policy No. 5300(6)(a) prohibits such board from discharging, demoting or transferring an employee for reasons having to do with prior misconduct or incompetency that has not been called to the attention of the employee through evaluation and which is correctable. Syl. pt. 3, Trimboli v. Board of Educ., 254 S.E.2d 561 (W.Va. 1979).
      3.      OCBE failed to meet its burden of proof that five cited incidents of Grievant's conduct were considered by it to be immoral acts at the time each one occurred or to otherwise demonstrate that such conduct, while inappropriate and perhaps unprofessional, constituted immorality.
      4.      OCBE's failure to provide Grievant an opportunity to improve his counseling performance prior to dismissal was contrary to the requirements of Policy No. 5300(6)(a) that an employee be offered an improvement period for incompetency or correctable misconduct. Mason County Bd. of Educ. v. State Supt. of Schools, 274 S.E.2d 435 (W.Va. 1980).

      Accordingly, the grievance is GRANTED and Ohio County Board of Education is ordered to reinstate Grievant under an improve ment plan and pay him appropriate back wages less any set off for interim earnings.

      Either party may appeal this decision to the Circuit Court of Kanawha County or to the Circuit Court of Ohio County and such appeal must be filed within thirty (30) days ofreceipt of this decision. W.Va. Code §18-29-7. Neither the West Virginia Education and State Employees Grievance Board nor any of its Hearing Examiners is a party to such appeal, and should not be so named. Please advise this office of any intent to appeal so that the record can be prepared and transmitted to the appropriate court.

DATE: April 30, 1991      ____________________________
      NEDRA KOVAL
                         Hearing Examiner


Footnote: 1
The principal's testimony related to an event which was cited as the eleventh incompetency charge in OCBE's dismissal letter. Neither of the parties addressed this incident in their level four fact/law proposals.
Footnote: 2
Dr. Hill testified that when Grievant's illness was unchecked, Grievant could be prone to displaying a lack of inhibitions, sexually provocative conduct or other atypical behavior.
Footnote: 3
Grievant also argued that in accordance with W.Va. Code §18- 5-18b, school counselors must spend seventy-five percent of their work time in a direct counseling relationship and no more than one- fourth of the work-day in counselor-related administrative activities. He claimed that the incompetency alleged by OCBE involves only twenty-five percent of his work, i.e., the time that he performs administrative duties, and that seventy-five percent of his work time in which he actually counsels students has not otherwise been criticized. Hence, seventy-five percent of his counseling performance is satisfactory, according to Grievant.
Footnote: 4
OCBE noted that Grievant placed a "different spin" on the last incident which occurred at Morgantown when he testified at level four that he had used the term "laid out" to mean that the student may have "passed out" from drinking too much. It discounted Grievant's level four version as being at odds with what occurred when Grievant was confronted by Messrs. Carder and Krelis. At that time he had said his statement had been a joke.
Footnote: 5
It claims this is so "even after the most liberal interpretation of the principles" in Bledsoe v. Wyoming County Bd. of Educ., 394 S.E.2d 885 (W.Va. 1990); Meckley v. Kanawha County Bd. of Educ., 383 S.E.2d 839 (W.Va. 1989); Rovello v. Lewis County Bd. of Educ., 381 S.E.2d 237 (W.Va. 1989); Golden v. Harrison County Bd. of Educ., supra; and Beverlin v. Bd. of Educ. of Lewis County, 216 S.E.2d 554 (W.Va. 1975).
Footnote: 6
"The rational nexus test contained in Syllabus Point 2 of Golden v. Board of Educ,, 169 W.Va. 63, 285 S.E. 2d 665 (1981), applies exclusively to 'acts performed at a time and place separate from employment.'" Syl. Pt. 4, Bledsoe v. Wyoming County Bd. of Educ., 394 S.E.2d 885 (1990). Thus, contrary to Grievant's assertion otherwise, the Morgantown incident appears to be the only conduct which would be subject to analysis under Golden's rational nexus test since the other alleged "immoral" acts did occur on the job.
Footnote: 7
The Trimboli Court also held, at 566, that "evaluation and opportunity to improve [is] a mandatory function of every board ofeducation, and [a] right of every board employee."
Footnote: 8
It must be noted that OCBE apparently employs two different sets of evaluation formats, perhaps in alternate years. For 1987- 88 and 1989-90, the evaluator was to indicate "yes" if there was "strong evidence the standard was performed" or "no" if there was "no evidence" of performance. For 1986-87 and 1988-89, "some" was included as a rating area and was to be marked if there was "some evidence that the standard is performed." Notably, in Grievant's 1988-89 evaluation, the fourteen areas or "indicators" in which standards were not met were all marked "some" and none were marked "no."