An additional lawsuit has been filed against the Raleigh County Board of Education and a former Independence Middle School science teacher, claiming a third female minor was sexually exploited.

The complaint, filed July 6, names “Jane Doe #3” as the plaintiff and claims that she was induced into “an inappropriate and illegal amorous relationship” with Michael Jason Dickens.

According to the complaint, Dickens utilized his position as a teacher to attempt to induce Jane Doe #3 into “an illegal amorous relationship for his personal sexual gratification” both during school hours and on school property.

Dickens allegedly asked her to come to his classroom for “purposes of sexual discussion and sexual interaction which involved kissing, hugging and fondling.”

The following year, Jane Doe #3 was a sophomore at Independence High School. The suit claims that Dickens arranged meetings with Jane Doe #3 in his automobile and while together, he made sexual comments, attempted to fondle her, and “placed [her] hand on his genitals for his personal sexual gratification.”

The relationship allegedly continued through her junior year, when in the fall of that year she met with Dickens’ wife and let her hear a sexually explicit voicemail message left by Dickens.

Dickens’ wife then contacted a teacher at Independence High seeking advice, according to the suit, and the two then approached IMS principal Terry Poe with the information about the relationship between Dickens and Jane Doe #3 and potentially other students.

The complaint alleges that Dickens was given a “verbal reprimand” from Poe and he suggested Dickens and his wife attend church.

Poe did not bring the allegations to the attention of the Raleigh County Board of Education, according to the suit.

During the same month,  Jane Doe #3 met with IHS principal David Severt and Poe to discuss the allegations, according to the complaint, and her parents were neither notified of the claims or notified of the meeting.

Dickens was arrested by West Virginia State Police June 9, 2011, for “soliciting a minor via computer.”

The Raleigh County Board of Education declined comments to the local media, stating that the allegations “did not involve the school.”

Two days after Dickens’ arrest, Poe announced his early retirement.

Two similar complaints have been filed and the West Virginia State Police Crimes Against Children Unit is actively investigating other possible instances of sex crimes by Dickens while employed at IMS.

The complaint suggests that the board knew or had reason to know that Dickens was engaging in relationships with students as early as 2003.

The plaintiff is being represented by two Charleston law firms: Preston and Salango, and Olivio and Griffith. They are seeking compensation for pain and suffering, past and future, emotional and mental anguish, humiliation and embarrassment and other damages.

A trial by jury has been demanded.

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