STATE OF FLORIDA EDUCATION PRACTICES COMMISSION DR. TONY BENNETT, as Commissioner of Education, Petitioner, vs. CASE NO. 112-3098 PATRICK STEWART ORANE, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Dr. Tony Bennett, as Commissioner of Education, files this Administrative Complaint against PATRICK. STEWART ORANE. The Petitioner secks the appropriate disciplinary sanction of the Respondent’s educator’s certificate pursuant to Seetions 1012.315, 1012.795, and 1012.796, Florida Statutes, and pursuantto Rule 6A-1 0.081, 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 lL. The Respondent holds Florida Educator’s Certificate 887973, covering the area of Exceptional Student Education, which is valid through June 30, 2016. 2, At all times pertinent hereto, the Respondent was employed as an Exceptional Education Teacher at Miami Senior High School in the Miami-Dade County: School District. MATERIAL ALLEGATIONS 3. On.or about January 20, 2012, a parent of 12” grade Exceptional Edueation student E.G. requested a meeting with the Respondent to discuss allegations that the Respondent had grabbed or pulled F.G. The Respondent observed F.G.’s parents speaking to the school resource officer. The Respondent yelled or shouted the following statements, or words to that effect, to B.G.’sparents in the presence of the officer and students: (a) “You called the police on me?.” PATRICK STEWART ORANE Administrative Complaint Page 2 of 3 (6) “I’m going to fuck you up;” and (¢) “Fuck you!” 4, On or about May 16, 2012, Miami-Dade County School Board dismissed the Respondent from his employment. 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)(g), Florida Statutes, in that Respondent has been found guilty of personal conduct which seriously reduces: his effectiveness as ‘an employee of the school board, COUNT3: The Respondent is in violation of Section 1012.795(1)G), 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 4: The allegations of misconduct set forth herein are in violation of Rule 6A- 10,081(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 5: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081 (3)(e), Florida Administrative Code, in that Respondent has intentionally exposed a student to unnecessary embarrassment or disparagement. COUNT 6: The Respondent is in violation of Rule 6A-10.081(5)(0), Florida Administrative Code, in that Respondent sought reprisal against any individual who. has reported an allegation ofa violation of the Florida School Code or State Board of Education Rules as defined in Section 1012.795(1), Florida Statutes. (SIGNATURE ON FOLLOWING PAGE) PATRICK STEWART ORANE 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 fora period of time not to exceed five years; revoking the Respondent’s educator’s certificate for a period of time up to 10 yeats 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 petmanently, nd. . EXECUTED on this 22 day of __ tas l , 2013, DR. TONY BENNETT as Commissioner of Education State of Florida

Docket for Case No: 13-003702PL