STATE OF FLORIDA EDUCATION PRACTICES COMMISSION TOM GALLAGHER, as Commissioner of Education, Petitioner, CD-5! 24 AL vs. CASE NO. 990-0219-C STEVEN LARSEN, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Tom Gallagher, as Commissioner of Education, files this Administrative Complaint against Steven Larsen. 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 1. The Respondent holds Florida Educator’s Certificate 712766, covering the areas of History and Social Science, which is valid through June 30, 2000. - 2. At all times pertinent hereto, the Respondent was employed as a Social Studies teacher at Mariner High School, in the Lee County School District. MAT L_ALLEGAT 3. On or about June 12 ,1998, Respondent operated his vehicle while he was intoxicated. Respondent was arrested and charged with Driving Under the Influence. On or about December 16, 1998, Respondent pled Not Guilty and was found not guilty of the criminal offense by a jury. 4. On or about March 1, 2000, Respondent ‘operated his vehicle while he was intoxicated. Respondent was arrested and charged with Driving Under the Influence. Respondent po | Steven Larsen Administrative Complaint 2 of 2 was in an accident and upon investigation was found to have a blood alcohol level higher than the legal limit. ; STATUTE VI I COUNT 1: The Respondent is 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 Respondent is 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 Respondent is in violation of Section 231.28(1)(f), Florida Statutes, in that Respondent has been found guilty of personal conduct which seriously reduces his effectiveness as an employee of the school board. COUNT 4: The Respondent is in violation of Section 231.28(2), Florida Statutes, which provides that the plea of guilty in any court or the decision of guilty by any court is prima facie proof of grounds for the revocation of the certificate. 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, permanent 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_/( 7% dayof_ (Cb 200. Commissioner of Education State of Florida

Docket for Case No: 00-005124PL