STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, VS. CASE NO. 112-1704 RICHARD LOUIS, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against RICHARD LOUIS. 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 Educator’s Certificate 788710, covering the area of Social Science, which is valid through June 30, 2018. 2, At all times pertinent hereto, the Respondent was employed as an Economics and American Government Teacher at Northwestern High School in the Miami-Dade County School District. MATERIAL ALLEGATIONS 3, In June of 2010, Respondent improperly changed the grades of a student, Respondent submitted a grade change form improving student C.L.’s final grade and exam grade in Respondent’s American Government Course. Respondent did not have proper justification in the form of additional school work by C.L. or other documentation to justify the grade changes. 4. The grade change forms were used to authorize changes to C.L.’s official transcript, improving C.L.’s grades and making him eligible for a scholarship from the National RICHARD LOUIS Administrative Complaint Page 2 of 3 College Athletic Association (NCAA). C.L. was not aware that his grades were improperly changed. 5. Upon discovering the discrepancies in C.L.’s grades, the NCAA determined that C.L. did not qualify for his scholarship, and C.L. was removed from his college football team. 6. On or about April 18, 2013, Respondent inappropriately touched a student when he pinched, poked and rubbed the back of 18-year-old, female student, A.K, during class, When AK. pushed Respondent’s hand away from her, Respondent continued to rub A.K.’s back. Respondent’s behavior made A.K. uncomfortable. 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 involving moral turpitude as defined by rule of the State Board of Education. 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. COUNT 3: The Respondent is in violation of Section 1012.795(1)G), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession prescribed by State Board of Education rules. RULE VIOLATIONS COUNT 4: — 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 3: 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. COUNT 6: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(3)(h), Florida Administrative Code, in that Respondent has exploited a relationship with a student for personal gain or advantage. COUNT 7: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(5){a), Florida Administrative Code, in that Respondent has failed to maintain honesty in RICHARD LOUIS Administrative Complaint Page 3 of 3 all professional dealings. COUNT 8: The Respondent is in violation of Rule 6A-10.081(5)(h), Florida Administrative Code, in that Respondent has submitted fraudulent information on a document in connection with professional activities. 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 thé Education Practices Commission impose an appropriate sanction agairist 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 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 the Respondent from reapplying for an educator’s certificate for a period of time up to 10 years or permanently, EXECUTED on this 2 \ dayor_ (level, 2014 PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 15-004991PL