alle ll le Fe ae oe ee eee _or abo a sao tonmrcovaetn scr ‘we . ; . (Biggin of Administrative Hearings STATE OF FLORIDA TOM GALLAGHER, as Commissioner of Education, oo _{l 2 oa Petitioner, OD oa vs. CASE NO. 989-0745-M ALFRED L. WASHINGTON, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, TOM GALLAGHER, as Commissioner of Education, files this Administrative ~ Complaint against Alfred L. Washington. The Petitioner seeks the appropriate disciplinary sanction “- of the Respondent’s educator’s certificate pursuant to Sections 231.262 and 231.28, Florida Statutes, and pursuant to Rule 6B-1.006, Florida Administrative Code, Principles of Professional Conduct for the Education Profession in Florida, said sanctions specifically set forth in Sections 231.262(6) and 231.28(1), Florida Statutes. The Petitioner alleges: ~ _ JURISDICTION OL The Respondent holds Florida Educator’s Certificate 707720, covering the areas of Mathematics, which is valid through June 30, 1999. 2. At all times pertinent hereto, the Respondent was employed as a Mathematics teacher at Royal Palm Beach High School, in the Palm Beach County School District. " MATERIAL ALLEGATIONS — 3. On or about April 14, 1998 Respondent fondied ‘a minor female student, $.L., in his classroom. On or about May 8, 1998, Respondent was arrested and charged with Lewd Assault. On abo jovember , 1998, Respondent was terminated from his employment with the Palm beach ‘County School Board. On or about January 5, 1999, Respondent was adjudicated guilty by the court, and sentenced to twenty-one months incarceration in the Department of Corrections with fifty-seven days credit. tai QW Ww f " Ep ww 00 Map vee Alfred L. Washington “8 py Administrative Complaint ; oe Vis le: ee: , Page 2 of 3 STATUTO i S UNGS [2 COUNT 1: The allegations of misconduct set forth herein are in violation of Section 231.28(1)(c), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude. ; COUNT 2: The allegations of misconduct set forth herein are in violation of Section 231.28(1)(e), Florida Statutes, in that Respondent has been convicted of a misdemeanor, felony, or other criminal charge, other than a minor traffic violation. COUNT 3: The allegations of misconduct set forth herein are in violation of Section 231.28(1)(f), Florida Statutes, in that Respondent, upon investigation, has been found guilty of personal conduct which seriously reduces his effectiveness as an employee of the school board. COUNT 4: The allegations of misconduct set forth herein are in violation of Section 231.28(1)Q), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct _ for the Education Profession in Florida prescribed by State Board of Education. COUNT 5: Section 231.28(2), Florida Statutes, provides that the plea of guilty in any court or a decision of guilty by any court is prima facie proof of grounds for the revocation of the ” certificate. RULE VIOLATIONS Le eee COUNT 6: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(a), Florida Administrative Code, in that Respondent has failed to make reasonable effort to protect the student from conditions harmful to learning and/or to the student’s mental health and/or physical safety. ; sancoures CQUNT 7: The allegations of misconduct set forth herein are in violation of Rule 6B- _. 1,006(3)(e), Florida Administrative Code, in that Respondent has intentionally exposed a student to unnecessary embarrassment or disparagement. ~ COUNT 8: The allegations of misconduct set forth herein are in violation of Rule 6B- 1,006(3)(h), Florida Administrative Code, in that Respondent has exploited a relationship with a student for personal gain or advantage. m ann apgmene ee . Alfred L. Washington Administrative Complaint Page 3 of 3 WHEREFORE, the Petitioner recommends that the Education Practices Commission impose an appropriate penalty pursuant to the authority provided in Sections 231.262(6) and 231.28(1), Florida Statutes, which penalty may include a reprimand, probation, restriction of the authorized scope of practice, administrative fine, suspension of the teaching certificate not to exceed three years, *“perianent revocation of the teaching certificate, or combination thereof, for the reasons set forth herein, and in accordance with the Explanation and Election of Rights forms which are attached hereto and made a part hereof by reference. EXECUTED on this 22 day of_A0OVEmBen— __, 1999. Commissioner of Education, State of Florida Ww

Docket for Case No: 00-001030