STATE OF FLORIDA EDUCATION PRACTICES COMMISSION DR. ERIC J. SMITH, as Commissioner of Education, Petitioner, vs. CASE NO. 101-0824 DARLENE CAMPBELL, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Dr. Eric J. Smith, as Commissioner of Education, files this Administrative Complaint against DARLENE CAMPBELL. 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 604231, covering the area of Mathematics, which is valid through June 30, 2013. 2. At all times pertinent hereto, the Respondent was employed as a Mathematics Teacher at Madison Middle School in the Miami-Dade County School District. MATERIAL ALLEGATIONS 3. On or about April 29, 2010, the Respondent directed J.M., a twelve year-old male student, to leave her classroom. J.M. asked the Respondent to return J.M.’s pen. The Respondent hit J.M. in the lip after J.M. attempted to grab the pen. The Respondent then grabbed J.M. by his shirt and pushed J.M.. 4. On or about May 7, 2010, the Respondent denied the request of K.D., a twelve year- ld male student, to go to the restroom. When K.D. attempted to leave the classroom, the Respondent grabbed K.D. by the shirt and pushed him on the shoulder or neck area. Filed October 17, 2011 9:18 AM Division of Administrative Hearings DARLENE CAMPBELL Administrative Complaint Page 2 of 3 The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1 )(j), 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 2: | 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 3: 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. (SIGNATURE ON FOLLOWING PAGE) DARLENE CAMPBELL 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. EXECUTED on this \are day of Apei ( , 2011. Commissioner of Education State of Florida

Docket for Case No: 11-005321PL