— sehen Sane nea ELAN Pe STATE OF FLORIDA EDUCATION PRACTICES COMMISSION JIM HORNE, as La dh. Commissioner of Education, TRS Petitioner, vs. Case Number: 023-1037-Q JERRY EDWARD JONES, mah taeda {’ Respondent. [ u | ay if L- / ADMINISTRATIVE COMPLAINT Petitioner, Jim Horne, as Commissioner of Education, files this Administrative Complaint against JERRY EDWARD JONES. The Petitioner seeks the appropriate disciplinary sanction of the Respondent's educator's certificate pursuant to Sections 1012.795 and 1012.796, Florida Statutes, and pursuant to Rule 6B-1006, Florida Administrative Code, Principles of Professional Conduct for the Education Profession in, Florida, said sanctions specifically set forth in Sections 1012.795(1) and 1012.796(7), Florida Statutes. The Petitioner alleges: JURISDICTION nue 1. The Respondent holds Florida educator's certificate 530517, covering the areas of Educational Leadership, Mathematics and Sociology which is valid through June 30, 2006. 2. At all times pertinent hereto, the Respondent was employed as an Assistant Principal at Dundee Ridge Middle School in the Polk County School District. MATERIAL ALLEGATIONS MALE Eee 3. On or about April 4, 2002, the Respondent physically manhandled a minor male student, using excessive force. 4. The Respondent was arrested and charged with Battery. On or about JERRY EDWARD JONES Administrative Complaint Page 2 of 3 November 6, 2003, the Respondent agreed to enter a deferred prosecution program. The Respondent was administratively reassigned to work in the transportation department of the Polk County School District and prohibited from holding a position with direct student contact until July 31, 2003. STATUTE VIOLATIONS COUNT 1. The allegations of misconduct set forth herein are in violation of Section 1012.795(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 1012.795(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 failed to make reasonable effort to protect the student from conditions harmful to learning and/or to the student's mental 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. WHEREFORE, the Petitioner recommends that the Education Practices Commission impose an appropriate penalty pursuant to the authority provided in Sections 1012.795(1) and 1012.796(7), 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. JERRY EDWARD JONES Administrative Complaint Page 3 of 3 EXECUTED on this BH Bray of May 2004. Horne, as ommissioner of Education, State of Florida

Docket for Case No: 04-004347PL