STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 112-2325 JOHN DURHAM WILLIAMS, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against JOHN DURHAM WILLIAMS. 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 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 Educatot’s Certificate 1129112, covering the area of Athletic Coaching, which was valid through June 30, 2013. 2, Atall times pertinent hereto, the Respondent was employed as a Coach at Fernandina Beach High School in the Nassau. County School District. MATERIAL ALLEGATIONS 3. During the fall of 2011, members of the Fernandina High School wrestling team engaged in hazing activities in the school’s wrestling locker room. The activities included, but were not limited to, the following: a) paddling the new wrestlers with wooden paddles; b) shooting the new wrestlers with pellet guns; and JOHN DURHAM WILLIAMS Administrative Complaint Page 2 of 3 ¢) restraining the new wrestlers and slapping theit stomachs (a/k/a “red bellies”). 4, On. one occasion, during a team fund-raiser, one student wrestler, R.W., was forced by other members of the wrestling team to wear a singlet, A senior wrestler forced R.W. to undress in public and punched R.W. repeatedly. Other senior wrestlers put R.W.’s clothes into a tree. When R.W. climbed the tree to retrieve his clothes, he was stung by wasps. 5, On one occasion, Respondent found plastic gun pellets on the floor of the wrestling locker room. Respondent told bis wrestlets, “Whoever’s gun it is, get rid of it,” or words to that effect. Respondent failed to report the incident to administration and failed to otherwise ensure the safety of the members of his wrestling team. 6. During the fall of 2011, as a result of the various hazing activities described herein, several student wrestlers quit the wrestling team. 7. In December 2011, the school conducted an investigation into the hazing activities. The wrestling program was suspended until after Winter Break. On or about January 12, 2012, Respondent was removed as the Head Wrestling Coach. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1)(g), Florida Statutes, in that Respondent has been found guilly of personal conduct which seriously reduces his effectiveness as ari employee of the school board. COUNT 2: The Respondent is in violation of Section 1 012.795(1)(j), Florida Statutes, iin 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(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. (SIGNATURE ON FOLLOWING PAGE) JOHN DURHAM WILLIAMS 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 eéducator’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; assessirig 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 ineli gible 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 “TP day or November, 2013. PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 14-001761PL