STATE, OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as — Commissioner of Education, Petitioner, vs. . CASE NO. 112-1755 CHRISTIAN LAMAR SIMMONS-COOPER, . Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against CHRISTIAN LAMAR STMMONS-COOPER. 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 oOL The Respondent holds Florida Educator’s Certificate 1158155, covering the area of Social Science, which is valid through June 30, 2013. 2. Atall times pertinent hereto, the Respondent was employed as a Paraprofessional at Baldwin Middle Senior High School in the Duval County School District. MATERIAL ALLEGATIONS 3. Between February and April of 2011, the Respondent engaged in sexual activity with a female student under the age of 18. On or about April 21, 2011, the Respondent was arrested and charged with two counts of Sexual Battery and one count of Lewd or Lascivious Molestation. On or about July 25, 2012, the Respondent pled guilty to two counts of Sexual Battery and was adjudicated guilty. The Respondent was sentenced to 24 months incarceration and directed to register as a sexual offender. The charge of Lewd or Lascivious Molestation was dropped. CHRISTIAN LAMAR SIMMONS-COOPER - Administrative Complaint Page 2 of 3 4. On or about April 19, 2011, the Duval County School District terminated the Respordent’s employment. : 5. The Respondent’s coriviction of Sexual Battery under Section 794.011, Florida Statutes, disqualifies the Respondent from certification pursuant to Section 10 42.315(1)(u), Florida Statutes. 6. Pursuant to Section 1012.795(2), Florida Statutes, the plea of guilty in any court or the decision of guilty by any court is prima facie proof of grounds for the revocation or other sanction of a teaching certificate. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1 (4), 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)(Q), Florida Statutes, in that Respondent has been convicted or found guilty of, or entered a plea of guilty to, regardless of adjudication of guilt, a misdemeanor, felony, or any other criminal charge, other than a minor traffic violation. : COUNT 3: The Respondent is subject to Section 1012.795(1)(n), Florida Statutes, in that Respondent has been disqualified from educator certification under 1012.315, Florida Statutes. (SIGNATURE ON FOLLOWING PAGE) CHRISTIAN LAMAR SIMMONS-COOPER Administrative Complaint Page 3 of 3 WHEREFORE, based on the reasons set forth heremn 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 012.796(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 oe day of Dale mlose 2012. PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 13-000114PL