STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, VS. CASE NO. 112-3117 JOHN SEBASTIAN CONTOUPE, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against JOHN SEBASTIAN CONTOUPE. 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 I. The Respondent holds Florida Educator’s Certificate 607893, covering the areas of English and Middle Grades, which is valid through June 30, 2014. 2. At all times pertinent hereto, the Respondent was employed as a Language. Arts Teacher at Port St. Lucie High School in the St: Lucie County School District. MATERIAL ALLEGATIONS 3. At all times pertinent hereto, Respondent bred dogs and shipped dogs to buyers across state lines. A valid health inspection certificate is required to ship a dog via a commercial airline across state lines. 4, On or about October 16, 2010, Respondent shipped Jackson; a dachshund, by commercial airline, from, Florida to buyer Gail Richards in Missouri. Jackson was accompanied with a “State of California” health certificate. that included Respondent’s name and contact information, the name of the purchaser, and a description of Jackson. The certificate also JOHN SEBASTIAN CONTOUPE Administrative Complaint Page 2 of 3 indicated that “Dr. Drew Lawrence” had, examined and vaccinated Jackson at the “San Jose Animal Hospital” on October 14, 2010. Jackson was never examined by a “Drew Lawrence” in the state of California or anywhere else, 5. On or about May 18, 2012, in Okeechobee County, Florida, Respondent was atrested and charged with Count 1: Forgery or Uttering a False Animal Health Certificate, Count 2: Offering An Animal For Sale Without Proper Health Requirements, and Count 3: Offering An Animal For Sale Without Certificate of Veterinary Inspection. 6. On or about December 5, 2012, the court withheld adjudication. with respect to Count 1. An order of nolle prosequi was entered with respect to Count 2 and Respondent was adjudicated guilty of Count 3. Respondent was sentenced.to five (5) years of probation and was ordered to pay restitution to Ms, Richards in the amount of $2,050. 7. On, or about October 24, 2012, the St, Lucie County School District placed Respondent on administrative leave without pay pending the outcome. of the criminal charges. On or about January 14, 2014, the St. Lucie County School District adopted the Recommended Order in Division of Administrative Hearings case nurnber 13-0410TTS, terminating Respondent’s employment. 8. Pursuant to Section 1012.795(2), Florida Statutes, the plea of guilty or the decision of guilty by a court is prima facie proof of grounds for revocation or other sanctions. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1)(f), Florida Statutes, in that Respondent has been convicted or found guilty of or entered a plea of guilty to, regardless of adjudication of guilt, a misdemeanor, felony, or any other criminal charge, other than a minor traffic violation. 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 effectiveness as an employee of the school board, (SIGNATURE ON FOLLOWING PAGE) JOHN SEBASTIAN CONTOUPE 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 6n 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 the Respondent from reapplying for an educator’s certificate for a period of time up to 10 years or permanently, EXECUTED onthis_ Z| dayof. Pipes | 2014, PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 15-000586PL