STATE OF FLORIDA DIVISION OF ADMINISTRATIVE HEARINGS WILLIAM V. HUSFELT, as Superintendent of Schools, District of Bay County, Florida, Petitioner. BCSB Case No. 15-01 vs. DOAH Case No. KATHERINE SLIMP, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, William V. Husfelt, as Superintendent of Schools, District of Bay County, Florida (the “Superintendent”), files this Administrative Complaint against Katherine Slimp, Respondent. The Petitioner seeks the appropriate disciplinary sanctions against the Respondent pursuant to Chapter 120; Section 1012.33, Florida Statutes; and the policies of the Bay District School Board. The Petitioner alleges as follows: 1, The Respondent is employed as a teacher at Arnold High School for the School District of Bay County. 2. The Respondent is classified as instructional staff and a continuing contract employee under the Master Contract between the Bay District School Board and the Association of Bay County Educators (the “Collective Bargaining Agreement”). 3. On or about October 21, 2014, a student reported to his parent and the assistant administrator that Respondent had called him a “worthless piece of crap.” 4. When asked about the incident, Respondent confirmed the student’s statement, but claimed she left off the last word. Respondent was counseled on expectations of professional behavior and offered options on how to handle the situation differently. 5. On or about November 4, 2014, students reported to the assistant principal that Respondent engaged in unprofessional communications with several students in her classroom. These communications included telling a student “I don’t know where your vagina has been” after the student claimed that she placed her cell phone there and another comment about placing a stick on a another student’s rear end to make sure he “didn’t fall into” the vagina. 6. When asked about the incident, Respondent confirmed the students’ statements, but claimed that the whole class was making sexual jokes at the time and that the student she made the stick comment to was 18. nm 7. The next day another student reported to the assistant principal that Respondent pulled him aside and asked him if he had “any dirt on other teachers” to get administration off her back. 8. On November 7, 2014, the Superintendent suspended Respondent with pay and scheduled an informal hearing with Respondent. A copy of the Supcrintendent’s letter to the Respondent is attached as Exhibit “A.” 9. On November 10, 2014, Respondent met with the Superintendent to discuss the circumstances surrounding the allegations. 10. On November 12, 2014, the Superintendent continued Respondent’s suspension and recommended that the School Board proceed toward terminating Respondent’s employment. A copy of the Superintendent’s letter to the Respondent is attached as Exhibit “B.” 11. On November 18, 2014, the Bay District School Board heard and accepted the Superintendent’s recommendation to suspend the Respondent without pay and to proceed to terminate her employment. A copy of the Superintendent’s recommendation to the Board is attached as Exhibit “C.” 12. On November 20, 2014, by Certified Return Receipt Mail, counsel for Bay District School Board notified Respondent of the Board’s decision and Respondent’s right to request an administrative hearing. A copy of the School Board Attorney’s letter to the Respondent is attached as Exhibit “D.” 13. On December 1, 2014, Respondent's attorney requested an administrative hearing via email. A copy of Respondent's attorney's email to the Petitioner's attorney is attached as Exhibit “E..” 14. The allegations set forth herein establish good and sufficient reasons to terminate the employment of the Respondent under her contract with the Bay District School Board, the Collective Bargaining Agreement, Florida Statutes, the Code of Ethics of the Florida Department of Education and the policies of the Bay County School Board. WHEREFORE, Petitioner recommends that the School Board of Bay County, Florida uphold the suspension of the Respondent and dismiss her as an employee of said School District for the reasons set forth above. DATED this 7 day of January, 2015. / } ? nal (4 ie é Pe ce WILLIAM V. HUSFELT ERT C. JACKSON Superintendent of Schools Florida Bar No. 0149519 School District of Bay County, Florida Harrison Sale McCloy 304 Magnolia Avenue Post Office Box 1579 Panama City, Florida 32402-1579 raicksond LHISMeLaw.com tadkins @ FISMeLaw.com Telephone: (850) 769-3434 Facsimile: (850) 769-6121 Attorneys for Petitioner CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint was e-mailed to Anthony D. Demma, Esq. at tdemma@ meyerbrookslaw.com, this 9°_ day of January, 2015. oberf C. Jackson Wituiast V. HusFeELT JIT SUPERINTENDENT 1311 Ba'boa Avenue Panama City, Florida 32401-2080 (850) 767-4100 tearing Impaired Access (800) 955-8770 Voice (800) 955-8771 TOD way. bay.k12.fL.us Board Members: Jerry Register District 1 Ginger Littleton District 2 Joe Wayne Walker District 3 Ryan Neves District 4 Steve Moss District 5 November 7, 2014 Mrs. Katherine Slimp P.O Box 18186 Panama City Bch., FL 32417 Dear Mrs. Slimp: Effective today, you are suspended with pay per School Board Policy #4.113. I have scheduled an informal hearing with you on Monday, November 10, 2014, at 4:00 p.m. in my office. Please feel free to bring union representation to that meeting if you desire. Sincerely, William V. Husfelt Superintendent Bay District Schools CC: Keith Bland, Principal Personnel File EXHIBIT 1 A Wiuuaw V. HusFeLt HIE SupERINTENDENT 1311 Balboa Avenue Panama City, Florida 32401-2080 {850) 767-4100 Hearing Impaired Access {800) 955-8770 Voice (800) 955-8771 TOD wiv bay.k12.fl.us Board Members: Jerry Register District 1 Ginger Littleton District 2 Joe Wayne Walker District 3 Ryan Neves District 4 Steve Moss District 5 November 12, 2014 Mrs. Katherine Slimp P.O. Box 18186 Panama City Beach, FL 32417 Dear Mrs. Slimp: You are currently suspended with pay and I will be recommending that you be suspended without pay and that the district move toward your termination at the School Board meeting scheduled for November 18, 2014. A personnel hearing for you has been scheduled for that day at 1:30 p.m. and you may choose to speak at that hearing with, or without, union representation. You may also choose to resign your position with Bay District Schools at any time before the personnel hearing commences. Please feel free to contact me if you have any questions or need additional information. Sincerely, William V. Husfelt Superintendent ce. Keith Bland, Principal of J.R. Arnold High School Personnel File EXHIBIT 1 8B Wituan V. Husrett 11 SUPERINTENDENT 1311 Balboa Avenue Panama City, Florida 32401-2080 (850) 767-4100 Hearing Impaired Access (800) 955-8770 Voice (800) 955-8771 TDD www.bay.k12.fl.us Board Members: Jerry Register District 1 Ginger Littleton District 2 Joe Wayne Walker District 3 Ryan Neves District 4 Steve Moss District 5 TO: School Board Members and Attorneys FROM: William Husfelt, Superintendent \\s : RE: Recommendation DATE: November 12, 2014 At the November 18, 2014 Board Meeting | will be recommending that Katherine Slimp be suspended without pay pending termination for “misconduct in office.” |am making this recommendation based on the fact that Mrs. Slimp violated: 1. The Code of Ethics from the Florida Department of Education. Specifically 3(a), 3(e), 3(g) which relate to protecting students from unnecessary embarrassment or disparagement. 2. School Board Policy 3.141 which relates to inappropriate comments to students. cc. Personnel File Keith Bland, Principal of J.R. Arnold High School EXHIBIT ic HARRISON SALE McCLoy FRANKLIN R. HARRISON fhattison@HSMclaw.com CORRESPONDENCE Postal Drawer 1$79, Panama City, FL 32402 PANAMA CITY OFFICE SANDESTIN OF FICE 304 Magnolia Avenue 495 Grand Blvd. Suite 206 Attorneys At Law Panama City. FL 32401 Miramar Beach, FL 32550 T 850.769.3434 F 850.769.6121 T 650.269.7218 November 20, 2014 VIA REGULAR AND CERTIFIED MAIL RECEIPT NO. 7011 3500 0001 1446 8445 Ms. Katherine Slimp Post Office Box 18186 Panama City Beach, Florida 32417 Dear Ms. Slimp: On November 18, 2014, the Bay County School Board accepted the Superintendent’s recommendation that you be suspended without pay and proceed to terminate your employment with the Bay County School Board. If you desire an administrative hearing before an administrative law judge pursuant to §§120.569 and 120.57, Florida Statutes and School Board policy 1.105, please notify this office within twenty-one (21) days of reccipt of this letter. Any request should be directed to the Bay County School Board, c/o Franklin R. Harrison, Post Office Drawer 1579, Panama City, Florida 32402. Should the School Board not receive a timely request for a hearing, you will be terminated as an employee. Very truly yours, MIG ST yp oN ; aa ECCLL-U Franklin R. Harrison FRH/ss ec: William V. Husfelt, Superintendent Sharon Michalik, Executive Director for Human Resources Anthony D. Demma, Esq. Ncholas A. Beninate + Gtandon A Burg + J. Cole Davis + Robert A. Fleming, IN + Feanklin R. Harasan » Heather K. Hudson + Mobest C Jackson + Andrew B, levy Dion Ross McCloy, Jr + Dion J. Monuz - Amy F. Myers + Kevin 0. Obos, Uhackee + C. Andrew Weddle » H. Alan Thompson (1937 -2006) EXHIBIT Pos

Docket for Case No: 15-000147TTS