In Harmon v. Mifflin County School District, 651 A.2d 681 (Pa. Cmwlth. 1994), a school board accepted the recommendation of the Director of Buildings and Grounds and terminated a school custodian for violating school rules. The school district's solicitor, who was present at the meeting when the school board decided to terminate the custodian, also prosecuted the case on behalf of the district administration, while another attorney conducted the school board hearing and advised the board in its decision. After the school board upheld the termination, the custodian appealed, and the trial court reversed. The trial court held that, because of the solicitor's ongoing relationship with the school district, his prosecution of the case created the appearance of impropriety. The Court recognized that the due process protections needed in Lyness-type cases are not required in every case. The Court established a "continuum of due process rights" approach, observing that: "The type of due process hearing that is required is dependent upon the forum, the relationship of the parties, the interests at stake and should be consistent with the goal of reducing the risk of arbitrary government action." Harmon, 651 A.2d at 685.