- and 231. 2615(1), Eh i The Petitioner alleges: SPATE OF FLORIDA ' OE EDUCATION PRACTICES COMMISSION’ ADMINISTRATIVE COMPLAINT Petitioner, Charlie Crist, as Commissioner of Education, files this Administrative Complaint against Donna Gowers. The Petitioner seeks the appropriate disciplinary sanction of the. Respondent’s educator’s certificate pursuant to Sections 231.262 and 231.2615, 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) JURISDICTION 1> - The Respondent holds Florida educator’s certificate 269375, covering the areas of sdninitatonsuperiston, and English, which is valid through June 30, 2002. ‘At all times pertinent hereto, the Respondent was employed asa a Principal at t Miami Ki ian Senior} High School, in the Dade: County Schoo! District. MATERYAL ALLEGATIONS 3. “On or about May 21, 2000, Respondent learned of an inappropriate te relationship between a Christopher M. Nunez, a teacher at Miami Killian Senior High School, and a 17-year-old- female student, LR. Respondent failed to immediately report the relationship to the site or region supervisor as required by school board policy. As a consequence, Mr. Nunez was able to commit sexual battery against L:R. on the afternoon of May 22, 2000, at the school. — , sion oF Administrative tive Hearings | CHARLIE CRIST, as | - Commissioner of Education, 5 (— (0 wl Petitioner. Time. nore tmerneerenena Ione OV . vs. oO CASENO,-001-H86-V¥—— DONNA GOWERS, ~ Respondent, / PERCE remeron eee Division of Adminisirati Ve Hear Ings Donna Gowers x ‘Administ tive Complaint Or eer ete eee aesterey, XLATION S_YI%/- | COUNT 1: The Respondent i is in violation of Section 231. 2615(i)(e), 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 231.2615(1)(i), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession Prescribed by State Board of Education rules. RULE VIOLATIONS COUNT 3: 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 health and/or safety. “COUNT 4: 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. “5: “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. WHEREFORE, the Petitioner recommends that the Education Practices Commission impose an’ “appropriate penalty pursuant to the authority provided in Sections 231.262(6) and 231.2615(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 1 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 2 dayot MARCH 2001, CHARLIE CRIST, as Commissioner of Education State of Florida - 20f2 | segpape WNT ps <8 prmemes Ae Ne Te

Docket for Case No: 01-001597PL