THE SCHOOL BOARD OF BROWARD COUNTY, FLORIDA

Donnie Carter,

Interim Superintendent of Schools,

Petitioner, PETITION FOR FORMAL PROCEEDINGS

v.

DARREN JONES,

Respondent.

                                                I

ADMINISTRATIVE COMPLAINT

Petitioner, Donnie Carter, Interim Superintendent of Schools of Broward County, Florida, through his undersigned counsel, Law Offices of Carmen Rodriguez, P.A., files this Administrative Complaint, pursuant to Chapters 120, 1001, and 1012 of the Florida Statutes, as well as Chapters 6B-1 and 6B-4 of the Florida Administrative Code, and states the following:

1. Jurisdictional Basis

   
   

   1. The agency is the School Board of Broward County, Florida, located at 600 Southeast Third Avenue, Fort Lauderdale, Broward County, Florida 33301.

   2. The Petitioner is Donnie Carter, who is the Interim Superintendent of Schools of Broward County, Florida.

   3. The Petitioner is statutorily obligated to recommend the placement of school personnel and to require compliance and observance with all laws, rules, and regulations. Any violation thereof shall be reported with the appropriate disciplinary action against any school personnel failing to comply therewith, inclusive of the Respondent, Darren Jones (hereinafter

      
      

      1

      
      

      Filed August 31, 2011 8:10 AM Division of Administrative Hearings

      "Jones").

      
      

   4. Respondent Jones is an employee of the Broward County School Board and is currently employed as a principal at Hallandale High School.

   5. The last known address of the Respondent, Darren Jones, is 10293 S.W. 55th Lane, Cooper City, Florida 33328.

2. Specific Charges

   The Petitioner Donnie Carter, alleges as follows:

   
   

   1. Respondent Jones, a high school principal, engaged in inappropriate conduct by

      
      

      engaging in child abuse and/or aggravated child abuse against his 16 year old daughter, which

      
      

      was inappropriate and contrary to the provisions of Florida law cited herein. On or about January 2011, Jones was arrested on charges of Aggravated Child Abuse, a first degree felony, against his daughter. See Fla. Stat. §827.03(2)(A). Specifically, Jones intentionally and willfully struck his daughter numerous times with an extension cord and caused bruising and scarring to her arms, legs, and back. Child Protective Services ("CPIS") determined that this case was one of "extreme child abuse."

   2. Respondent Jones engaged in intentional infliction of physical injury upon his own child by willfully striking, torturing and/or maliciously punishing his daughter. Upon information and belief, this abuse was premeditated and a pattern within the household. Jones admitted to striking his daughter as a means of punishment. Jones' other daughter (11 years old) stated to CPIS that her and her brother (6 years old) are typically disciplined with a belt or brush and that Jones had struck his daughter with a cord that day because he could not find his belt.

      
      

3. Just Cause

   
   

   Just cause exists for the requested relief pursuant to § 1012.33 Fla. Stat., the Respondent's employment contract, School Board rules and regulations, the Code of Ethics of the Education Profession, and the Employee Disciplinary Guidelines promulgated by the School Board, including but not limited to the following:

   1. Moral turpitude: The Respondent, through his above-described conduct, violated § 1012.33 Fla. Stat., and Rule 68-4.009(6) of the Florida Administrative Code, and the baseness, vileness, and depravity of his actions constitute moral turpitude in violation of the social and private duties to which he owed his fellow man and society both in general and as an educator.

      Additionally, the Respondent's above-described conduct further violates the Code of Ethics of the Education Profession, Rule 68-1.001, 68-1.006, Florida Administrative Code. The Respondent's conduct, as factually set forth herein, is sufficiently notorious to bring the Respondent and/or the education profession into public disgrace or disrespect and impair the Respondent's service in the community.

   2. Immorality: The Respondent, through his above-described conduct, violated§ 1012.33 Fla. Stat., and Rule 68-4.009(2) of the Florida Administrative Code, and his actions constitute immorality, which is conduct inconsistent with the standards of public conscience and good morals.

Additionally, the Respondent's above-described conduct further violates the Code of Ethics of the Education Profession, Rule 68-1.001, 6B-1.006, Florida Administrative Code.

The Respondent's conduct, as factually set forth herein, is sufficiently notorious to bring the Respondent and/or the education profession into public disgrace or disrespect and impair the Respondent's service in the community.

WHEREFORE, based upon the foregoing, the Petitioner, Donnie Carter, Interim Superintendent of Schools, recommends that the School Board, subsequent to providing requisite notice, dismiss the Respondent, Darren Jones, from his employment as a high school principal based upon the foregoing facts and legal authority.

Dated: July tl, 2011

Interim Superintendent of Schools

Respectfully submitted: Carmen Rodriguez, Esquire Cadre Attorney

Docket for Case No: 11-004413TTS