STATE OF FLORIDA EDUCATION PRACTICES COMMISSION £6 J!) 13 a 3 “8 on. ‘49 JOHN L. WINN, as Commissioner of Education, Petitioner, vs. Case Number 034-06 va ° SELWYN G. BROWN, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, John L. Winn, as Commissioner of Education, files this Administrative Complaint agains) SELWYN G. BROWN. 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 1. The Respondent holds Florida educator's certificate 685733, covering the areas of Educational Leadership and Business Education which i is valid through June 30, 2008. 2. At all times pertinent hereto, the Respondent was employed as an Assistant Principal at Whiddon-Rogers Education Center in the Broward County School District. MATERIAL ALLEGATIONS 3. Over the course of one or more school years commencing in April 2001, the Respondent engaged in an ongoing pattern of sexual harassment of A. B., a female employee under his supervision. This harassment included inappropriate comments, exposure of his genitals, solicitation of sexual favors and use of his supervisory position SELWYN G. BROWN OO IIT 13 AM 9:6 Administrative Complaint Page 2 of 3 to pressure the employee to endure his inappropriate sexual comments and actions. 4. Over the course of one or more school years commencing in 2001-2002, the Respondent engaged in an ongoing pattern of sexual harassment of L. M., a female employee at his school. This harassment included inappropriate comments, sexual advances, hugging and kissing the employee, constantly calling the employee at home and on her cellular telephone, and disrupting the employee’s marriage. 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)(f), Florida Statutes, in that Respondent, upon investigation, has been found guilty of personal conduct which seriously reduces that person’s effectiveness as an employee of the school board. COUNT 3. _ The allegations of misconduct set forth herein are in violation of Section 1012.795(1)(), 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 4. The allegations of misconduct set forth herein are in violation of Rule 6B-1.006(5)(d), Florida Administrative Code, in that Respondent engaged in harassment or discriminatory conduct which unreasonably interferes with an individual’s performance of professional or work responsibilities or with the orderly processes of education or which creates a hostile, intimidating, abusive, offensive, or oppressive environment; and further, Respondent failed to make reasonable effort to assure that each individual is 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 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 om yee . aut Os SELWYN G. BROWN OG MAN 1S AN St 46 Administrative Complaint Page 3 of 3 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_25 day of _( Lye 2005. ohn L. Winn, as Commissioner of Education, State of Florida

Docket for Case No: 07-000582PL