STATE OF FLORIDA EDUCATION PRACTICES COMMISSION GERARD ROBINSON, as Commissioner of Education, Petitioner, vs. CASE NO. 090-3007 JESUSA JUEN HAFFORD, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Gerard Robinson, as Commissioner of Educati on, files this Administrative Complaint against JESUSA JUEN HAFFORD. 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 788881, covering the areas of Elementary Education and English for Speakers of Other Languages (ESOL), which is valid through June 30, 2015. 2. At all times pertinent hereto, the Respondent was employed as an English for Speakers of Other Languages Teacher at McCoy Elementary School in the Orange County School District. MATERIAL ALLEGATIONS 3. On or about January 24, 2011, Respondent stated, in the presence of fifth grade de students, that Respondent was tired of fifth grade student G.A.’s “crap,” or words to that effect. 4. On or about January 24, 2011, Respondent asked fifth grade student L.V., in the presence of other fifth grade students, if L.V. was “stupid or deaf,” or words to that effect. Filed June 22, 2012 8:54 AM Division of Administrative Hearings JESUSA JUEN HAFFORD Administrative Complaint Page 2 of 3 5. During the 2010-2011 school year, Respondent pushed or tipped her fifth grade students’ desks or caused the students’ papers, books, schoo! supplies, and personal belongings to fall to the floor. Respondent then made the students pick up the items from the floor. 6. On or about May 4, 2011, Respondent stated to fifth grade student J.T., in the presence of other fifth grade students, “I don’t know how you made it to fifth grade,” or words to the effect. 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}{j), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession prescribed by State Board of Education rules. COUNT 3: 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 4: 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) JESUSA JUEN HAFFORD Administrative Complaint Page 3 of 3 WHEREFORE, based on the reasons sect 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 \ (ss day of Mary , 2012. Lead be GERARD ROBINSON, as Commissioner of Education State of Florida

Docket for Case No: 12-002192PL