Welch v. Board of Education of Chandler United School District No. 80 of Maricopa County
In Welch v. Board of Education of Chandler United School District No. 80 of Maricopa County, 136 Ariz. 552, 667 P.2d 746 (App. 1983), the court concluded that a teacher had acted unprofessionally even though "the record was devoid of any direct evidence that he was unfit to teach or that the district students were adversely affected by his conduct" and his official school evaluations showed that "he was more than satisfactory in performing his teaching duties." Id. at 554-55, 667 P.2d at 748-49.
The court determined that the teacher's act of lying to the school board upon its inquiry into his personal relationship with a former student constituted insubordination and unprofessional conduct. Id. at 555-56, 667 P.2d at 749-50.
The Court noted that:
We are unwilling to hold that a school board must demonstrate with particularity the adverse effects of a teacher's conduct upon his students, his teaching performance or the orderly running of the school as a prerequisite for dismissal in all circumstances. There may be conduct which by itself gives rise to reasonable inferences of unfitness to teach or from which an adverse impact on students can reasonably be assumed. Further, we are concerned that by imposing an absolute requirement that specific harm must be proven prior to dismissal, we would deter school administrators from acting to prevent or control predictable future harm. Id. at 555, 667 P.2d at 749.