STATE OF FLORIDA EDUCATION PRACTICES COMMISSION DR. TONY BENNETT, as Commissioner of Education, Petitioner, vs. CASE NO, 101-1673 KAREN BROUGHTON, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Dr. Tony Bennett, as Commissionet of Education, files this Administrative Complaint against KAREN BROUGHTON, The Petitioner seek the appropriate disciplinary sanction of the Respondent’s educator's certificate pursuant to Sections 1012.3 15, 1012.795, and 1012.796, Florida Statutes, and pursuantto Rule 6A-10.08 1, 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 L. The Respondent holds Florida Educator’s Certificate 925209, covering the areas of Reading and Family and Consumer Science, which is valid through June 30, 2016. 2. At all times pertinent hereto, the Respondent was employed as.a Reading Teacher at Washington High School in the Escambia County School District, MATERIAL ALLEGATIONS 3, During the 2009-2010 school year, the Respondent utilizéd the Escambia County School District electronic mail system to send e-mail messages to several employees of N.B. Cook Elementary School regarding a family member’s educational matters. The Respondent sent e-mails during the work day. The Respondent’s messages were harassing and intimidating, and were sent in retaliation for the employees’ participation in a district investigation, ; 4. Asaresult of the conduct alleged in paragraph 3, on or about November 1, 2010, the Escambia County Schoo! District issued the Respondent a letter of reprimand. KAREN BROUGHTON Administrative Complaint Page 2 of 3 The Petitioner charges: STATUTE VIOLATIONS COUNT I: 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 her otfectiveness as an employee of the school board, COUNT 2: The Respondetit is in violation of Section 1012.795(1)@), Florida Statutes, iti that Respondent has violated the Principles of Professional Conduct for the Education Profession prescribed by State Board of Education rules, RULE VIOLATIONS COUNT 3: The allegations of misconduct set forth herein are in violation of Rule 6A- 10,081(4)(a), Florida Administrative Code, in that Respondent has failed to take reasonable precautions to distinguish between personal views and those of any educational institution or organization with which the individual ig affiliated, COUNT 4: The allegations of misconduct set forth herein are in. violation of Rule 6A- 10.081(4\(c), Florida Administrative Code, in that Respondent has used institutional privileges for personal. gain or advantage, COUNT 5: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(5)(d), Florida. Administrative Code, in that Respondent has engaged in harassment or discriminatory conduct which unreasonably interfered with an individual’s performance of professional.or work responsibilities or with the orderly processes of education or which created. a hostile, intimidating, abusive, offensive, or oppressive environment; and further, failed to make reasonable effort to assure that each individual was protected from such harassment ot discrimination, (SIGNATURE ON FOLLOWING PAGE) KAREN BROUGHTON Administrative Complaint Page 3 of 3 WHEREFORE, based on the reasons set forth herein and in aecordance 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 Eclucation Practices Commission may inchide, but are not limited to, any one ora 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 tlie Resporident from reapplying for an educator's certificate for a period of time up to: 10 years. or permanently. EXECUTED on this Zi day of Mesch_. 2013, DR. TONY BENNETT as Commissioner of Education State of Florida

Docket for Case No: 13-003824PL