STATE OF FLORIDA EDUCATION PRACTICES COMMISSION JOHN-L. WINN, w O¥-530T PL Commissioner of Education, Petitioner, vs. CASE NO. 045-2538-T WILLIE JONES, JR., Respondent. peal 2 P / 22S s TT euo 3 iy ADMINISTRATIVE COMPLAINT = 3=— «FYI FE Pree Petitioner, John L. Winn, as Commissioner of Education, files this Admihistratiyé, Complaint against WILLIE JONES, JR.. The Petitioner seeks the appropriate disciplinary saif€tion of the Respondent’s educator’s certificate pursuant to Sections 1012.795 and 1012.796, 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 1012.795(1) and 1012.796(7), Florida Statutes. The Petitioner alleges: JURISDICTION 1. The Respondent holds Florida Educator’s Certificate 179802, covering the areas of Athletic Coaching, Biology and Chemistry, which is valid through June 30, 2009. 2. At all times pertinent hereto, the Respondent was employed as an Alternative Education Teacher at Apopka High School in the Orange County School District. MATERIAL ALLEGATIONS 3. Between January 1, 1999 and January 6, 2005, Respondent repeatedly harassed students by touching them in an inappropriate manner and making sexually suggestive comments directed at them. Respondent’s history reflects the following as evidence of his pattern of behavior: A. On or about August 27, 1999, Respondent rented a vehicle for a female student without obtaining the permission of her parents. A reprimand was issued. B. On or about January 12, 2000, Respondent inappropriately grabbed a student WILLIE JONES, JR. Administrative Complaint Page 2 of 3 and used inappropriate language when the student did not comply with Respondent’s instructions. A reprimand was issued. Cc. On or about November 19, 2004, Respondent inappropriately touched a female student by massaging her shoulders and fondling her hair. D. On or about January13, 2005, Respondent ran his fingers through the hair of a female student and made inappropriate comments about her appearance. A reprimand and directives were issued. E. On or aboutFebruary 17, 2005, Respondent forcefully grabbed a male student for singing in the restroom. This incident occuired immediately following the issuance of directives for the January 13, 2005 incident. A reprimand was issued. F. Respondent has made a significant number of girls uncomfortable by staring at them, sitting too close to them, rubbing up against them and putting his face directly in their face when he talks to them. STATUTE VIOLATIONS COUNT 1: The Respondent is 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 Respondent is in violation of Section 1012.795(1)(f), Florida Statutes, in that Respondent has been found guilty of personal conduct which seriously reduces his effectiveness as an employee of the school board. COUNT3: The Respondent is 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 4: 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 health and/or safety. COUNT 5: 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. WILLIE JONES, JR. Administrative Complaint Page 3 of 3 COUNT 6: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(g), Florida Administrative Code, in that Respondent has harassed or discriminated against a student on the basis of race, color, religion, sex, age, national or ethnic origin, political beliefs, marital status, handicapping condition, sexual orientation, or social and family background and shall make reasonable effort to assure that each student is protected from harassment or discrimination. WHEREFORE, based on the reasons set forth herein and in accordance with the Explanation of Rights and Election of Rights forms attached to and made a part of this Administrative Complaint, Petitioner respectfully recommends that the Education Practices Commission impose an appropriate sanction against the Respondent’s educator’s certificate pursuant to the authority provided in Sections 1012.795(1) and 1012.796(7), Florida Statutes. The sanctions imposed by the Education Practices Commission may include, but are not limited to, any one or a combination of the following: issuing the Respondent a written reprimand; placing the Respondent on probation for any period of time; restricting the Respondent’s authorized scope of practice; assessing the Respondent an administrative fine; directing the Respondent to enroll in the Recovery Network Program; suspending the Respondent’s educator’s certificate for a period of time not to exceed five years; revoking the Respondent’s educator’s certificate for a period of time up to 10 years or permanently; or barring the Respondent from reapplying for an educator’s certificate for a period of time up to 10 years or permanently. EXECUTED on this Z(» _dayof Ocdoleer _, 2006. HIN L. WINN, as Commissioner of Education State of Florida

Docket for Case No: 08-005207PL