STATE OF FLORIDA EDUCATION PRACTICES COMMISSION DR. ERIC J. SMITH, as Commissioner of Education, Petitioner, vs. CASE NO. 089-1772 JOHN PETER SALAMON, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Dr. Eric J. Smith, as Commissioner of Education, files this Administrative Complaint against JOHN PETER SALAMON. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educatot’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 583363, covering the areas of Health, Mentally Handicapped, and Physical Education, which is valid through June 30, 2012. 2. At all times pertinent hereto, the Respondent was employed as an Athletic Director and Varying Exceptionalities Teacher at Tavares High School in the Lake County School District. THOS 20aCher at i avar Ne Lake —_OUNTLY Of EPISEFIC MATERIAL ALLEGATIONS 3. On or about December 9, 2008, the Respondent approached J.S., a fifteen year-old female student who was seated at a computer in the media center. The Respondent leaned over J.S., cupped J.S.’s breast with his hand, kissed J.S.’s cheek, and told J.S. that he loved her. J.S. was surprised by the Respondent’s kiss and felt uncomfortable with the Respondent’s actions, which were done in the presence of other students. Filed September 1, 2011 11:20 AM Division of Administrative Hearings JOHN PETER SALAMON Administrative Complaint Page 2 of 3 4, Prior to December 9, 2008, the Respondent had engaged in inappropriate conduct towards femaie students. Specifically: (a) in December of 2008, the Respondent kissed H.P. on her cheek; (b) at the end of the 2007-2008 school year, the Respondent hugged H.P. and kissed her on the cheek; (c) the Respondent hugged J.D. and on one occasion kissed J.D. on the top of the head; and (d) the Respondent’s conduct caused female students to not want to be alone with the Respondent. 5. On or about July 21, 2010, the Respondent resigned from his position with the Lake County School District effective February 8, 2010. The Petitioner charges: TUTE VIOLATIO 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. COUNT3: The Respondent is 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(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. COUNTS: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3Xe), Florida Administrative Code, in that Respondent has intentionally exposed a student to unnecessary embarrassment or disparagement. JOHN PETER SALAMON Administrative Complaint Page 3 of 3 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. ry i 2. EXECUTED on this Wi day of Serre 2011. DR. E! J. SMOTH, as Comunissioner of Education State of Florida

Docket for Case No: 11-004440PL