touching nor quid pro quo sexual harassment." (Emphasis in original.) We also reject Jurgens's argument that North Pole's interest is somehow lessened by the fact that it has a progressive disciplinary policy. See NPMC 2.36.310(B). And we reject Jurgens's argument that North Pole has a "countervailing interest" in retaining a valuable employee like Jurgens. 53 . Coleman, 797 A.2d at 795 (quoting Meyers v. Montgomery County Police Dep't, 96 Md.App. 668, 626 A.2d 1010, 1028 (1993)). 54 . See In re Walton, 676 P.2d 1078, 1090 (Alaska 1983) (Rabinowitz, J., dissenting) ("If [the accused] is indeed innocent of the allegations made against him, the risk of wrongful discipline would be significantly reduced by using the clear and convincing evidence standard."). 55 . Walton, 676 P.2d at 1085 (<HOLDING>). 56 . Coleman, 797 A.2d at 795. The risk of
holding that standard for revocation of probation is preponderance of the evidence holding that the standard of proof in revocation proceedings is a preponderance of the evidence holding that the proper standard of proof is preponderance of the evidence holding that the standard of proof for dischargeability actions is the preponderance of the evidence standard holding that blecause there are substantial interests on both sides the risk of error should be borne equally that is accomplished by use of the preponderance of the evidence standard