In Morrison v. State Board of Education (1969) 1 Cal.3d 214, a public school teacher resigned after it became known he engaged in a homosexual relationship with another teacher. Thereafter the State Board of Education revoked his life diplomas pursuant to Education Code former section 13202, which authorized discipline for "'immoral or unprofessional conduct.'" (Morrison, at p. 217, fn. 1; see also id. at pp. 218-220.) The Supreme Court concluded terms such as "immoral," "unprofessional," or "involving moral turpitude" are too broad and amorphous to be used as a basis for the termination of a professional license. Rather, it must be shown the conduct in question indicates an unfitness to engage in the profession. The court explained: "Terms such as 'immoral or unprofessional conduct' or 'moral turpitude' stretch over so wide a range that they embrace an unlimited area of conduct. In using them the Legislature surely did not mean to endow the employing agency with the power to dismiss any employee whose personal, private conduct incurred its disapproval. Hence the courts have consistently related the terms to the issue of whether, when applied to the performance of the employee on the job, the employee has disqualified himself." (Morrison, supra, 1 Cal.3d at pp. 224-225.) The court concluded the State Board of Education could not abstractly characterize the conduct in the case as "immoral," "unprofessional," or "involving moral turpitude" within the meaning of Education Code former section 13202 unless that conduct indicated the petitioner was unfit to teach. (Morrison, at p. 230.) In that case, the California Supreme Court articulated criteria for assessing whether a teacher's conduct makes him or her unfit to teach. They include "the likelihood that the conduct may have adversely affected students or fellow teachers, the degree of such adversity anticipated, the proximity or remoteness in time of the conduct, the type of teaching certificate held by the party involved, the extenuating or aggravating circumstances, if any, surrounding the conduct, the praiseworthiness or blameworthiness of the motives resulting in the conduct, the likelihood of the recurrence of the questioned conduct, and the extent to which disciplinary action may inflict an adverse impact or chilling effect upon the constitutional rights of the teacher involved or other teachers." (Id. at p. 229.)