THE SCHOOL BOARD OF BROWARD COUNTY, FILORIDA Robert W. Runcie, Superintendent of Schools, Petitioner, PETITION FOR FORMAL PROCEEDINGS v. Randy Corinthian, Respondent. a / ADMINISTRATIVE COM PLAINT Petitioner, Robert W. Runcie, Superintendent of Schools of Broward County, Florida, through his undersigned counsel, Law Offices of Carmen Rodriguez, P.A., files this Administrative Complaint, pursuant to Chapters 120, 1001, and 1012 of the Florida Statutes, as well as Chapters 6B-1 and 6A-5 of the Florida Administrative Code, and states the following: 1, Jurisdictional Basis a. The agency is the School Board of Broward County, Florida, located at 600 Southeast Third Avenue, Fort Lauderdale, Broward County, Florida 33301, b. The Petitioner is Robert W. Runcie, who is the Superintendent of Schools of Broward County, Florida. . CQ The Petitioner is statutorily obligated to recommend the placement of school personnel and to require compliance and observance with all laws, rules, and regulations. Any violation thereof shall be reported with the appropriate disciplinary action against any school personnel failing to comply therewith, inclusive of the Respondent, Randy Corinthian (“Corinthian” or “Respondent’), d, Respondent Corinthian is an employee of the School Board of Broward County and is currently employed as an Music Teacher at Parkway Middle School, é Respondent, was employed, at all times material herein, by the School Board of Broward County, 2. Specific Charges The Petitioner Robert W. Runcie, alleges as follows: a D.C., a student in Respondent Corinthian’s music class, entered the classroom on April 26, 2012 and started playing the piano without a jack while standing. Respondent , proceeded to give D.C. a “F” for standing along with a directive to stop playing and get a jack. D.C. refused to comply with the directive and Respondent proceeded to give D.C. a second “F" to which D.C. told Respondent to “go fk yourself”. Respondent proceeded to give D.C. a third “F" and told him to leave, which D.C. tefused to do. Respondent calted security and grabbed D.C. by the back of the neck and placed him in a headlock to escort him out of the classroom throwing him into the hallway, : D.C. has been aggressively and purposely touched by Respondent approximately 20-21 times. b. It is not uncommon for Respondent to touch students in an inappropriate manner 2-3 times per week whether by placing in headlock, flicking their ears, giving “noogies,” placing students in a “full nelson” or just grabbing them and physically forcing them to sit down and/or leave the room. ¢. _ Aside from D.C., Respondent has also placed W.M. in a headlock on at least one occasion, after which he threw W.M. out of class as well. d. In addition to touching the students in an inappropriate manner, Respondent engages in inappropriate activities with the students as evidenced by his admittedly “shadow boxing” with a student during class, when the student stated he bet he could hit him, or words to that effect. Respondent retorted to the student that “I bet you can't” €. Respondent has previously been placed on notice that touching students is unacceptable, In 2011, while employed as a teacher at Boyd Anderson High School, complaints were received and Respondent was investigated for inappropriate contact with students and battery. The central allegations pertained to Respondent engaging in inappropriate conduct toward female students. While the battery charges were ultimately not sustained, probable cause was found for the inappropriate contact charge. As a result of this prior investigation, Respondent received a letter of reprimand and placed on notice that future conduct of this nature will result in further disciplinary action up to and including termination of employment. 3. Just Cause Just cause exists for the requested relief pursuant to § 1012.33 Fla. Stat., the Respondent’s employment contract, School Board rules and regulations, the Code of Ethics of the Education Profession, the Principles of Professional Conduct of the Education Profession, and the Employee Disciplinary Guidelines promulgated by the School Board, including but not limited to the following: Count t L Misconduct in office: Through his above described conduct, Corinthian has violated § 1012.33, Fla. Stat., and Rule 6A-5.056(2)(a), (b), and (c), Florida Administrative Code. His actions constitute misconduct in office as defined therein as he has committed clear violations of the Code of Ethics of the Education Profession outlined in Rule 6B-1.001(2) and (3) of the Florida Administrative Code; the Principles of Professional Conduct for the Education Profession in Florida outlined in Rule 6B- 1.006 (3)(a) and (e) of the Florida Administrative Code; School Board niles; disrupting the student's learning environment and reducing his ability to effectively perform his duties. Count 11 2. Incompetency: Corinthian through his above described conduct violated § 1012.33, Fla. Stat., and Rule 6A-5.056(3)(a)(2), Florida Administrative Code. His actions resulted in his inefficiency as a teacher as he has failed to communicate properly with and relate to students within his class, WHEREFORE, based upon the foregoing facts and legal authority, the Petitioner, Robert W, Runcie, Superintendent of Schools, recommends that the School Board, subsequent to providing requisite notice, terminate the Respondent, Randy Corinthian, from his employment. Dated: April___, 2013 “ Robert W. Runcie, Superintendent of Schools Respectfully submitted: Carmen Rodriguez, Esquire Cadre Attorney

Docket for Case No: 13-001506TTS