STATE OF FLORIDA eet EDUCATION PRACTICES COMMISSION OMAR 28 PHI2: 11 CHARLIE CRIST, as 2 Commissioner of Education, Petitioner, vs. CASE NO. 001-0173-M JOSEPHINE J. KNIGHT, 0% ~ QBPCO Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Charlie Crist, as Commissioner of Education, files this Administrative Complaint against JOSEPHINE J. KNIGHT. The Petitioner secks 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-1.001, Florida Administrative Code, Code of Ethics of the Education Profession in Florida, and Rule 6B-1.006, Florida Administrative Code, Principles of Professional Conduct for the Education Profession in Florida, and said sanctions specifically set forth in Sections 231,262(7) and 231.2615(1), Florida Statutes. The Petitioner alleges: JURISDICTION 1, The Respondent holds Florida Educator’s Certificate 602255, covering the areas of Elementary Education and English to Speakers of Other Languages, which is valid through June 30, 2003. 2. At all times pertinent hereto, the Respondent was employed as a 3rd Grade Teacher at St. Lucie Elementary School in the St. Lucie County School District. MATERIAL ALLEGATIONS 3. On or about February 13, 1998, the parents of one of Respondent's 4th grade students, K.P. and C.P., submitted a letter to the Superintendent of the St. Lucie County Schools alleging that Respondent made inappropriate and verbally abusive comments to her students. On or about October 28, 1997, she yelled at their son, R.P., in front of the entire class until he cried, causing other students to call him a "baby," or words to that effect, in class. On or about J. anuary 28, 1998, she yelled at J.P., calling him "stupid," and "slow," and telling him that he “would not get out of the fourth grade," or words to that effect. K.P. and-C.P. further alleged that on February 5, 1998, JOSEPHINE J. KNIGHT Administrative Complaint Page 2 of 3 Respondent told her entire class that they were "stupid idiots," or words to that effect, and that once during the 1997-1998 school year, she once told her class that she is "smarter and has more education than all the parents put together," or words to that effect. 4. On or about August 19, 1999, Respondent engaged in inappropriate, harassing conduct toward a colleague. She submitted a resignation letter to J.H., school principal, in which she made statements to the effect that her employment conditions were ones which "no one should be subjective [sic] to in the workplace" and that the conditions "almost define going postal.” J.H. interpreted the phrase "going postal" as a threat of violence to herself, the school staff, and the students. 5. On or about August 23, 1999, Respondent requested that her resignation letter be rescinded. On or about August 24, 1999, her resignation letter was rescinded and Respondent was suspended without pay by the St. Lucie County School District. On or about October 6, 1999, the District notified Respondent that she should be recommended for termination at the next School . Board meeting scheduled for October 26, 1999. On or about Au gust 25, 1999, Respondent requested a formal hearing with the District. On or about August 18, 2000, an Administrative Law Judge issued a Recommended Order finding just cause for the Respondent's termination from the School Board. 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)(f), Florida Statutes, in that Respondent, upon investigation, has been found guilty of personal conduct which seriously reduces her effectiveness as an employee of the school board. COUNT 3: 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 the State Board of Education. RULE VIOLATIONS COUNT 4: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.001(3), Florida Administrative Code, in the Respondent has failed to be aware of the importance of maintaining the respect and confidence of her colleagues, of students, of parents and of other members of the community and that Respondent has failed to achieve and sustain the highest degree of ethical conduct. JOSEPHINE J. KNIGHT Administrative Complaint Page 3 of 3 COUNT 5: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(5)(d), Florida Administrative Code, in that Respondent has engaged in harassment or discriminatory conduct which unreasonably interfered with an individual’s performance of professional or work responsibilities or with the orderly processes of education or which created a hostile, intimidating, abusive, offensive, or oppressive environment; and further, failed to make reasonable effort to assure that each individual was protected from such harassment or discrimination. - ; WHEREFORE, the Petitioner recommends that the Education Practices Commission impose an appropriate penalty pursuant to the authority provided in Sections 231.262(7) 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 onthis_/7) dayof December _, 2002. arlie Crist, as Commissioner of Education, State of Florida

Docket for Case No: 03-001123PL