Feb 20 200? 14:42 MAY - 86-2804 G2:83 From: To: 8589216847 P.S79 STATE OF FLORIDA EDUCATION PRACTICES COMMISSION. Sep -7 PH 1:24 JOHN L. WINN, as Commissioner of Education, Petitioner, vs. CASE NO. 023-0977-B JUDY C. KARPIS, () TOF OF P Respondent. ADMINISTRATIVE COMPLAINT Petitioner, John L_ Winn, as Commissioner of Education, files this Administrative Complamt against JUDY C. KARPIS. The Pelitioner seeks the appropriate disciplinary sanction of the Respondent's educator's cerlificale pursuant to Sections 1012 795 and 1012.796, Flonda Statutes, and pursuant to Rule 6B-1 006, Flonda Administrative Codc, Principics 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 Cerulicate 533960, covering the area of ~ Dental Assistant, which 1s valid through June 30, 2009 2. At all times pertinent hereto, the Respondent was employed as a Teacher at Dr. Michael M. Krup Senior High Schoo! and Norland Middle School in the Miann-Dade C ounty School District. MATERIAL ALLEGATIONS 3 During the 1999-2000 and 2001-2002 schooi years, Respondent rece: ved overall unsatisfactory evaluations al two different schools. Respondent also received numerous letters of reprimand for unprofessional behavior; battery on students and staff, inappropriate discipline; demeaning comments and intentional disparagement of students; threats and harassment of. colleagues, administration, and parents; frequent absences, insubordination; and interfering with investigations and witnesses. Examples of Respondent's hehavior include, but are not limited to: Feb 20 200° 14:42 MAY -@6-2884 G2:43 From: To :85@9216847 P.6°9 CHES amen ; : JUDY C. KARPIS 05 SEP -7 pH is 2h Admuinistrat ve Complaint Page 2 of 4 a. grabbing a 12-year-vld female student's arm and digging hei nails into the studept’s skin! b refusing to allow a female student to go to the bathroom after being informed that shc had started menstruation, causing the student to soil herself and be humiliated in front of the class; c scratching a tcacher’s aide on the ann with a sharp metal abject, causing the aide to blecd and require a telanus shot, d. punching a male student in the chest, then threatening to wnte a referral fos the student if he wrole 4 statement about tt, e demanding that the ESE counselor tear up student statements about her behavior, and offenng to tear up student referrals in exchange, f. referring a student to the offic for allegedly threatening to shoot Respondent with a gun, when Respondent did not hear the student say anything of that nature, g. screaming al parents during conferences, and h. repeatedly blowing a police whistle at her students for over an hour. 4. As arcsult of Respondent's behavior, a lage number of students were removed from her class. and administration received frequent ora! and written complaints from parents, teachers, and other staff, requesting that Respondent be removed [rom the school. On or about June 10, 2002, the schoo! board placed Respondent on altemate home assignment On or about May 29, 2003, Respondent resigned. On or about June 19, 2003, the schoo} board notified Respondent that she was precluded from future cmployment with the distnict. STATUTE VIOLATIONS COUNT 1: The Respondent 1s in violation of Section 1012.795(1)(c), Florida Statutes, in that Respondent has heen guilty of gross immorality o1 an act mvolving moral turpitude. COUNT 2: The Respondentis in violation of Section 1012.795(1)(f), Florida Statutes, in that Respondent has been found guilty of personal conduct which senously reduces her effectiveness as an cmployee vf the school boaril. COUNT3: The Respondents in violation of Section 101 2.795(1)(i), Florida Statutes, in Feb 20 2007 14:42 MAY-@6-2884 2:83 From: To:8589216847 P.7/9 1 at WES vo lal : JUDY C. KARPIS gcep-7 PH 1:24 ; 05 SEP 7 Pi Administrative Complaint Page 3 of 4 that Respondent has violated the Principles of Professional Conduct for the Education Profession prescribed by State Board of Education mules. RULE VIOLATIONS COUNT 4: The allegations of misconduct set forth herem are in violation of Rule 6B- 1.006(3)(a), Florida Administrative Code, in thal Respondent has failed to make rcasonable effort to protect the student from conditions hannful to lcarniny and/or to the student’s mental health and/or physical health and/or safety. COUNTS; The allegations of misconduct sel forth herein are in vialahon of Rule 6B- 1.006(3)(c), Florida Administrative Code, in that Respondent has intentionally exposed a student lo unnecessary embarrassment or disparagement. COUNT 6: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.000(3)(f), Florida Administrative Code, m that Respondent has intentionally violated or denied a student’s legal rights. COUNT 7: The allegations of misconduct set forth herem are in violation of Rule 6B- 1.006(3)(g), Florida Administrative Code, m that Respondent has harassed or discriminated against a student on the basis of race, color, religion, sex, age, national or ethmec ongin, political beliets, marital status, handicapping condition, sexual onentation, or social and family background and shall make reasonable effort to assure that each student is protected from harassment or discrimination. COUNT 8 : The alleyations of misconduct set forth herein are in violation of Rule 6B- 1.006(4)(e), Flonda Administrative Cade, in that Respondent has offered gratuity, gift, or favor to obtain special advantages COUNT 9: The allegations of misconduct set forth here: are in violation of Rule 6B- }.006(5)(a), Flanda Administrative Code, in that Respondent has failed to maintain honesty in all professional dealings COUNT 10: The allegations of misconduct set forth herem are in violation of Rule 6B- 1.006(5)(d), Florida Administrative: Codc, in that Respondent has engaged in harassment or discriminatory conduct which unreasonably interfered with an individual’s performance of professional or work responsibiliucs or with the orderly processes of education or which erated a hostile, intimidating, abusive, olfensive, or oppressive environment; and further, failed to make reasonable effort to assure that each individual was protected from such harassment or disermmination. COUNT 11: The allegations of misconduct set forth herein are in violation of Rule 6B- Feb 20 2007 14:43 MAY-@6-28@04 G2:04 From: T0:8589216847 P.8’9 Ctiecs ‘ WN , JUDY C. KARPIS 05 SEP-7 PM 1:24 Admmustratrve Complant Page 4 of 4 1.006(5)(e), Florida Administrative Code, in that Respondent has made malicious or intentionally false statements about a colleague. COUNT 12: The allegations of misconduct sct forth hercin are in violation of Rule 6B- 1.006(5)(S), Florida Administrative Code, in that Respondent has used coercive means or promised spccial treatment to influence professional judgments of colleagues COUNT 13: The Respondent:sin violation of Rule 6B. 1006(5)(0), l‘londa Adnunistrative Code. in that Respondent sought reprisal against any individual who has reported an allegation of a violation of the Flonda School Code or State Board of Education Rules as defined in Section 1012.795(1), Florida Statutes. WHEREFORE, the Petitioner recommends that the Education Practices Commission impose an appropriate penalty pursuant to the authority provided in Sections 1912.795(1) and 1012.796(7), Florida Statutes, which penalty may include a reprimand, probation. rcstnction of the authorized scope of practice, administrative finc, suspension of the teaching certificate not to cxcecd three years, permanent revocation of the teaching certificate, or combination thereof, for the reasons set forth herein, and im accordance with the Explanation and Election of Rights forms which arc attached hereto and made a part hereof by reference. EXECUTED on this__2 2 dayof Jade 2005 JOHN L. WINN, as Comunissioner of Education State of Florida

Docket for Case No: 07-000909PL