Is There A Requirement For A School District To Have A Policy Which Explicitly Prohibits Situations That Could Result In Disciplining Individuals ?

In Bolden v. Chartiers Valley School District, 869 A.2d 1134 (Pa. Cmwlth. 2005), a bus supervisor employed by the district inadvertently brought a gun to school and was disciplined by the school district. The bus supervisor claimed that the district did not have a formal policy prohibiting such inadvertent conduct. This court, relying on an unemployment case wherein the employer also did not have a formal policy prohibiting certain conduct, stated: There is no requirement that a school district have a policy specifically prohibiting every circumstance that could result in discipline. Indeed, where common sense dictates that certain actions are grounds for discipline, we have held in other contexts that there need not be a policy prohibiting such conduct .... See, e.g. DeNardis v. Unemployment Compensation Board of Review), 76 Pa. Commw. 212, 463 A.2d 116; 76 Pa. Commw. 212, 463 A.2d 116 (Pa. Cmwlth. 1983) (employer need not have a policy prohibiting the use of company property for personal use because no such policy is necessary for an employee to understand the wrongfulness of that conduct).