STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, VS. CASE NO. 112-0070 JANET 8. THOMAS, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against JANET S. THOMAS. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educator’s certificate pursuant to Sections 1012.315, 1012.795, and 101 2,796, Florida Statutes, and pursuant to Rule 6A-10.081, 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 1. The Respondent holds Florida Educator’ s Certificate 1055372, covering the areas of English for Speakers of Other Languages (ESOL) and Music, which is valid through June 30, 2018. 2. At all times pertinent hereto, the Respondent was employed as a Music Teacher at Southside Middle School in the Duval County School District. MATERIAL ALLEGATIONS 3. During the 2010-2011 school year the Respondent engaged in inappropriate and unprofessional conduct with students in her class in that she: (a) referred to disruptive students as “ignorant black folk”; (b) made’ the comment to students that “these niggers are never going to make it in my class”; JANET &. THOMAS Administrative Complaint Page 2 of 3 (c) grabbed a male student by the arm and pulled him by. the arm as a means of directing his behavior: (d) grabbed another male student by the arm and pulled him out of his desk as a means of directing his behavior; and. (¢) grabbed a third male by the arm and pushed him back into his seat. 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 involvitig moral turpitude as defined by rule of the State Board of Education. COUNT 2: The Respondent is in violation of Section 1012.795(1)(), Florida Stattites, in that Responderit has violated the Principles of Professional Conduet 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(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 4: 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. (SIGNATURE ON FOLLOWING PAGE) JANET S. THOMAS 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 Coitinission 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 sanctidtis 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 writtert 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 wp to 10 years or permanently; determining the Respondent to be ineligible for certifi¢ation; 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 )Q day of December , 2013. Commissioner of Education State of Florida

Docket for Case No: 14-000878PL