STATE OF FLORIDA EDUCATION PRACTICES COMMISSION (4-30 B2PL DR. ERIC J. SMITH, as Commissioner of Education, Petitioner, vs. CASE NO. 078-3145 ROBERT JEREMY KRUG, Respondent. ADMINISTRATIVE COMPLAINT. Petitioner, Dr. Eric J. Smith, as Commissioner of Education, files this Administrative Complaint against ROBERT JEREMY KRUG. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educator’s certificate pursuant to Sections 1012.315, 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 883072, covering the area of Art, which is valid through June 30, 2012. 2. At all times pertinent hereto, the Respondent was employed as an Art Teacher at Bartram Trail High School in the St. Johns County School District. MATERIAL ALLEGATIONS 3. In or around February 2008, Florida law enforcement officers received intelligence that the Respondent may have been involved in illegal cultivation of marijuana. 4, On or about March 17, 2008, Florida law enforcement officers obtained a search warrant to search the Respondent’s home and executed the warrant. 5. On or about March 17, 2008, while law enforcement officers were searching the residence, the Respondent admitted to law enforcement officers, in substance, the following: ROBERT JEREMY KRUG Administrative Complaint Respondent has smoked marijuana for as long as he can remember; Respondent utilizes the attic of his residence to cultivate and harvest Marijuana; Respondent had built two separate rooms within the attic; a larger room for fully grown plants being prepared for harvest, and a smaller room for cultivating seedling plants; Respondent had built and designed the grow rooms, incorporating air conditioning, irrigation, ventilation, timing and lighting of the marijuana plants; Respondent obtained the majority of his knowledge of growing marijuana from magazine articles; Respondent grows sixty (60) to seventy (70) marijuana plants at a time; Respondent has set up the operation so that a mature crop of approximately thirty (30) marijuana plants may be harvested approximately every four (4) months; Respondent has been growing marijuana in his attic for almost one (1) year; Respondent sells harvested marijuana to his friends; Respondent sells the marijuana for $200 per ounce; Respondent keeps different strains of harvested marijuana in a refrigerator located in his garage; Respondent also keeps harvested marijuana in a refrigerator located in his kitchen; Respondent maintains approximately one (1) pound of harvested Marijuana for his own personal use; Respondent insisted that approximately $600 to $700 of the U.S. Currency located in Responderit’s residence is from the sale of Page 2 of 4 ROBERT JEREMY KRUG Administrative Complaint Page 3 of 4 marijuana; the rest is from Respondent selling his artwork; and Respondent grows marijuana as a hobby, to support his personal use of marijuana and as an extra source of income. 6. The search of the residence resulted in the following items being found as seized as evidence: A. — Miscellaneous Indoor Grow Equipment, including: . Grow Lamps; . Air Vent Filters; ° Generators; . Grow Blocks; . Air Conditioning Unit; . Plastic Trays; . Grow Products and Chemicals; B. _ Sixty-six (66) marijuana plants with root systems within the grow rooms; C. Approximately one (1) pound of processed marijuana, found in sixteen (16) individual Zip-lock baggies weighing 20 to 30 grams each, located in the garage refrigerator; D. —_ Approximately 176 grams of processed marijuana located in numerous glass, plastic and wooden containers throughout the residence; E. Numerous items of drug paraphernalia including metal pipes, glass bongs, etc., found throughout the residence; and F. $6,000 in bundled U.S. Currency located in the Respondent’s bedroom. 7. On or about March 17, 2008, the Respondent was arrested and charged with Manufacture of Cannabis and Possession of Paraphernalia. On or about June 11, 2008, the Respondent pled nolo contendere to these charges, and adjudication was withheld, The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1)(d), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude as defined by rule of the State Board of Education. COUNT 2: The Respondent is in violation of Section 1012.795(1)(g), Florida Statutes, in that Respondent has been found guilty of personal conduct which seriously reduces his effectiveness as an employee of the school board. ROBERT JEREMY KRUG Administrative Complaint Page 4 of 4 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; determining the Respondent to be ineligible for certification; 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 \S*™ day of LDece aber , 2008. Commissioner of Education State of Florida

Docket for Case No: 09-003022PL