DA-A TBS OC. STATE OF FLORIDA ts, EDUCATION PRACTICES COMMISSION an CHARLIE CRIST, as Commissioner of Education, Petitioner, vs. CASE NO. 001-1352-M PHILIP DE LEO BROWN, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Charlie Crist, as Commissioner of Education, files this Administrative Complaint against Philip De Leo Brown. 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) and 231.2615(1), Florida Statutes. The Petitioner alleges: JURISDICTION 1. The Respondent holds Florida Educator’s Certificate 776278, covering the area of Spanish which is valid through June 30, 2004. 2. At all times pertinent hereto, the Respondent was employed as a Spanish Teacher at Blanche Ely High School in the Broward County School District. PHILIP DE LEO BROWN Administrative Complaint Page 2 of 3 MATERIAL ALLEGATIONS 3. On or about December 7, 2000, Respondent hit A.P., a 16-year-old, male student, with a closed fist on the side of the student’s head. Thereafter, Respondent’s principal reassigned him to the guidance office, and ordered him to stay away from students and refrain from going to his classroom without permission. On or about December 15, 2000, Respondent was reassigned to a district office due to his failure to comply with his principal’s orders and concems about students harming him. On or about April 5, 2001, Respondent and the district entered into a Disciplinary Action and General Release Agreement in which Respondent accepted a letter of reprimand, agreed to attend an anger management course and received a 5 day suspension without pay. STATUTORY VIOLATIONS COUNT 1: | The allegations of misconduct set forth herein are in violation of Section 231.2615(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 ~. 231.2615(1)(i), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession in Florida prescribed by State Board of Education. 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 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. PHILIP DE LEO BROWN 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 231.2615(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 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 AS dayof fe brua , 2002. Charlie Crist, as Commissioner of Education, State of Florida

Docket for Case No: 02-002921PL