STATE OF FLORIDA DIVISION OF ADMINISTRATIVE HEARINGS WILLIAM V. HUSFELT, as Superintendent of Schools, District of Bay County, Florida, Petitioner, vs. Case No.: KEITH DAVID CHRISTIE, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, William V. Husfelt, as Superintendent of the School District of Bay County, Florida (the “Superintendent”), files this Administrative Complaint against Keith David Christie, Respondent. The Petitioner seeks the appropriate disciplinary sanctions against the Respondent pursuant to Chapter 120, Section 1012.33, Florida Statutes, Respondent’s Professional Services Contract, the Bay District School Board School Board Policy Manual, and the Master Contract between the Bay District School Board and the Association of Bay County Educators. The Petitioner alleges as follows: 1. The Respondent is employed by the School Board of Bay County, Florida as a teacher at J.R. Arnold High School. 2. Respondent’s employment is pursuant to a Professional Service Contract of Employment for Instructional Personnel of the Public Schools (“Professional Services Contract”) and the Master Contract between the Bay District School Board and the Filed July 17, 2012 10:50 AM Division of Administrative Hearings Association of Bay County Educators (“Collective Bargaining Agreement’’) and Florida Statute. 3. The Respondent is classified as professional services contract employee for purposes of the Bay District Schools School Board Policy Manual and the Collective Bargaining Agreement. 4. Pursuant to the Professional Services Contract, Article 12 of the Collective Bargaining Agreement, and Florida Statute 1012.33, respondent may dismissed at any time for “just cause,” as defined by Florida Statute 1012.33(1)(a). 5. Pursuant to Florida Statute 1012.33(1)(a) and Section 4.113 of the Bay District School Board School Board Policy Manual just cause includes “misconduct in office.” 6. Florida Administrative Code 6A-5.056 defines misconduct in office as “a violation of the Code of Ethics of the Education Profession as adopted in Rule 6B-1.001, F.A.C., and the Principles of Professional Conduct for the Education Profession in Florida as adopted in Rule 6B-1.006, F.A.C., which is so serious as to impair the individual’s effectiveness in the school system.” 7. In or around the middle of March, 2012, Respondent told a female Exceptional Student Education student suffering from a learning disability that he was “sick of your shit.” 8. As a result, shortly thereafter, the J.R. Arnold High School principal issued Respondent a verbal warning about appropriate interactions with students and classroom management. 9. On or around March 30, 2012 Respondent raised his voice to an autistic student and yelled comments asking if the student wanted to be struck in the face by Respondent. 10. Respondent on multiple occasions required his learning disabled Exceptional Student Education students to crawl on the floor and make pig noises as punishment for incorrect answers. 11. Respondent has counseled some students to quit school. 12. On April 5, Respondent was required to attend a meeting with J.R. Amold High School principal and the Bay District Schools Executive Director for Human Resources during which the items described by paragraphs 7-11 above were discussed. 13, On the day of that meeting, Respondent told his students that they would no longer do the pig activity, but instead would throw paper balls at students who provide incorrect answers. 14. Though additional incidents need not be considered for a dismissal decision, on November 14, 2008 Respondent was reprimanded for violating State Board of Education Rule 6B-1.1.006 by (a) sending a mass e-mail to colleagues on November 11, 2008 addressing them as a bunch of criminals, (b) sending an e-mail to the J.R. Amold High School principal during the 2007-2008 school year complaining that soccer games and scores were omitted from Monday Memos because soccer is not a “black man’s sport,” and (c) mocking a colleague’s teaching style in for of a classroom of students. 15. On April 9, 2012, the Respondent was given an informal hearing with the Superintendent to discuss the circumstances surrounding the allegations. 16. Asa direct result of the allegations, on April 26, 2012, the Superintendent suspended Respondent with pay until the next School Board Meeting held on May 8, 2012 for violation of School Board policies. A copy of the Superintendent’s letter to the Respondent is attached as Exhibit “A.” 17. On May 8, 2012, the Bay District School Board heard the Superintendent’s recommendation that the Respondent be suspended without pay. 18. At the meeting, the Bay District School Board accepted the Superintendent’s recommendation and voted to suspend the Respondent without pay and to proceed to terminate his employment. 19. On May 10, 2012, by Certified Return Receipt Mail, counsel for Bay District School Board notified Respondent of the Board’s decision and Respondent’s right to request an administrative hearing. A copy of the School Board Attorney’s letter to the Respondent is attached as Exhibit “B.” 20. On May 8, 2012, Respondent’s attorney requested an administrative hearing. A copy of Respondent’s Attorney’s letter to Bay District School Board is attached as Exhibit “C.” 21. The allegations set forth herein establish one or more violations the Code of Ethics of the Education Profession in Florida and the Principles of Professional Conduct for the Education Profession in Florida, specifically Subsections (3) and (5) of 6B-1.006, constituting misconduct in office that establishes just cause to terminate the employment of the Respondent under his Professional Services Contract, the Collective Bargaining Agreement, Bay District School Board School Board Policy Manual, and Florida Statutes. WHEREFORE, Petitioner recommends that the School Board of the District of Bay County, Florida uphold the suspension of the Respondent and dismiss him as an employee of said School Board for the reasons set forth above. DATED this _| day of July, 2012. Respectfully submitted, EZ Vy AL. ate. Comin WILLIA ; Sai ROBERT C. JACKSON Superintendent of Schools Florida Bar No. 0149519 School District of Bay County, Florida NICHOLAS BENINATE Florida Bar No. 0027487 Harrison Sale McCloy 304 Magnolia Avenue Post Office Box 1579 Panaina City, Florida 32402-1579 Telephone: (850) 769-3434 Facsimile: (850) 769-6121 ATTORNEYS FOR PETITIONER CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint was mailed via electronic mail to Martin F. Powell, mpowell@meyerbrookslaw.com, Meyer, Brooks, Demma and Blohm, P.A., 131 North Gadsden Street, Tallahassee, FL 32301, this [dl day of July, 2012. WsAn lor (Bes cbs NICHOLAS BENINATE

Docket for Case No: 12-002485TTS