THE BROWARD COUNTY SCHOOL BOARD, FLORIDA ROBERT W. RUNCIE, Superintendent of Schools, Petitioner, v. John R. LaCasse Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Robert W. Runcie, Superintendent of Schools of Broward County, Florida (“Petitioner”), files this Administrative Complaint against Respondent, John R. LaCasse (“LaCasse”). The Petitioner seeks five (5) days of suspension without pay of Respondent’s employment with the Broward County School Board (“BCSB”) , pursuant to Chapter 120 and Sections 1001.51, 1012.27(5), and 1012.33 Florida Statutes and Rule 6A-5.056 of the Florida Administrative Code. The “Petitioner alleges the following: I. JURISDICTIONAL BASIS 1. The agency is the School Board of Broward County, Florida, Located at 600 Southeast Third Avenue, Fort Lauderdale, Broward County, Florida 33301. 2. The Petitioner is Robert W. Runcie, who is the Superintendent of Schools of Broward County, Florida. 3. The Petitioner is statutorily obligated to recommend the placement of school personnel and to require compliance and Il. Til. observance with all laws, rules, and regulations. Petitioner is authorized to report and enforce any violation thereof, together with recommending the appropriate disciplinary action against any instructional personnel employed by the BCSB, inclusive of LaCasse. LaCasse is an employee of the Broward County School Board and is currently employed as a principal pursuant to an Annual Contract, issued in accordance with Section 1012.33, Florica Statutes (2014). The last known address of LaCasse is 777 S. Federal Highway, K-105, Pompano Beach, Florida 33062. BACKGROUND ALLEGATIONS This recommendation is based upon conduct occurring during the 2014-2015 school year. LaCasse was, and is, a principal at Nova High School (“Nova”). PREVIOUS DISCIPLINE LaCasse was first hired by the district on August 29, 1984. On or about April 3, 2003, LaCasse was issued a Letter of Reprimand for allowing the band teacher and students, accompanied by several parents, to go on a trip to England and France that was not approved. Iv. 10. 11. 12. ADMINISTRATIVE CHARGES Petitioner realleges and incorporates herein by reference the allegations set forth in paragraphs one (1) through nine (9) above. As principal of Nova, LaCasse is responsible for the performance of all personnel employed by the district school board and assigned to the school to which the principal is assigned. § 1012.28, Fla. Stat. As principal of Nova, LaCasse is subject to the Florida Principal Leadership Standards, which provide in part: (1) Purpose and Structure of the Standards. (a) Purpose. The Standards are set forth in rule as Florida's core expectations for effective school administrators. The Standards are based on contemporary research on multi-dimensional school leadership, and represent skill sets and knowledge bases needed in effective schools. The Standards form the foundation for school leader personnel evaluations and professional development systems, school leadership preparation programs, and educator certification requirements. (b) Structure. There are ten (10) Standards grouped into categories, which can be considered domains of effective leadership. Each Standard has a title and includes, as necessary, descriptors that further clarify or define the Standard, so that the Standards may be developed further into leadership curricula and proficiency assessments in fulfillment of their purposes. kk OK 3. Standard 8: School Management. Effective school leaders manage the organization, operations, and facilities in ways that maximize the use of resources to promote a safe, efficient, legal, and effective learning environment. The leader: a. Organizes time, tasks and projects effectively with clear objectives and coherent plans; 3 13. b. Establishes appropriate deadlines for him/herself and the entire organization; Cc. Manages schedules, delegates, and allocates resources to promote collegial efforts in school improvement and faculty development; and d. Is fiscally responsible and maximizes the impact of fiscal resources on instructional priorities. ek ke * (d) Domain 4: Professional and Ethical Behavior: 1. Standard 10: Professional and Ethical Behaviors. Effective school leaders demonstrate personal and professional behaviors consistent with quality practices in education and as a community leader. The leader: a. Adheres to the Code of Ethics and the Principles of Professional Conduct for the Education Profession in Florida, pursuant to Rules 6B-1.001 and 6B-1.006, F.A.C.; b. Demonstrates resiliency by staying focused on the school vision and reacting constructively to the barriers to success that include disagreement and dissent with leadership; c. Demonstrates a commitment to the success of all students, identifying barriers and their impact on the wel _-being of the school, families, and local community; d. Engages in professional learning that improves professional practice in alignment with the needs of the school system; e. Demonstrates willingness to admit error and learn from it; and £. Demonstrates explicit improvement in specific performance areas based on previous. evaluations and formative feedback. Rule 6A-5.080 of the Florida Administrative Code During the 2014-2015 school year, the Nova Debate Booster Club’s (“NDBC”) conducted up to $300,000 in financial transactions without depositing revenues received, dispersing expense payments from, and properly accounting for such transaction through Nova’s internal accounts, as required by School Board policy. lLaCasse acquiesced in the 4 14. 15. processing of those transactions outside of Nova’s internal accounts, and/or failed in his responsibility to ensure proper accounting through the internal accounts for such resources. During the 2014-2015 school year, NDBC co-mingled funds with the schools Debate club with regard to handling cash receipts, deposits and disbursements relating to fundraising, travel and activities for the school’s Debate program. LaCasse acquiesced in the processing of those transactions outside of Nova’s internal accounts, and/or failec in his responsibility to ensure proper accounting through the internal accounts for such resources. During the 2014-2015 school year, Linda Miller, Nova’s Debate teacher, (“Debate Teacher”) who was the sponsor of the Nova Debate Club (“NDC”) and also a member of the Nova Debate Booster Club (“NDBC”), engaged in the collection and disbursement of monies directly from the students and parents for travel, scholarships, and fundraising without complying with required accounting procedures. lLaCasse acquiesced in the processing of those transactions, and/or failed in his responsibility to ensure proper accounting for such transactions through the internal accounts for such resources. 16. 17. 18. During the 2014-2015 school year, the Debate Teacher operated a food concession called “The Closet”, in her classroom every day, during and after school hours. Such operation sold concession items all day long, in direct competition with the cafeteria and vending machine sales. LaCasse acquiesced in the processing of those transactions, and/or failed in his responsibility to ensure proper accounting through the internal accounts for such resources, as well as to ensure compliance federal regulations and School Board rules on sales of food. During the 2014-2015 school year, two parents were given credit cards to purchase snacks and sodas for resale from Costco, Sam’s, Club, Winn Dixie, etc. Each month they spent approximately $6,000 to replenish The Closet. During the 2014-2015 school year, on one or more occasions, the Debate Teacher directed her teenage daughters to walk to another school with thousands of dollars collected from The Closet to give to the Treasurer for deposit into the NDBC bank account. LaCasse acquiesced in the processing of those transactions, and/or failed in his responsibility to ensure proper accounting through the internal accounts for such resources, as well as preserve the safety of his students. 19. 20. 21. 22.. 23. LaCasse lied to auditors and investigators about his knowledge of The Closet operation, by claiming he had no knowledge that it was operating. During the 2014-2015 school year, LaCasse allowed the NDBC to use the School’s Sales Tax Exemption certificate when making purchases. During the 2014-2015 school year, LaCasse granted the Debate Teacher two supplements for sponsoring the Debate Club. During the 2014-2015 school year, the Debate Teacher used two personal credit cards when making travel arrangements for the Debate team, from which she benefited by obtaining frequent flyer miles or other incentives from the credit card companies instead, of paying them through the school’s internal funds. LaCasse acquiesced in the processing of those transactions, and/or failed in his responsibility to ensure proper accounting through the internal accounts for such resources, and maintenance of financial benefits for Nova. BASIS FOR DISCIPLINE Any member of the district administrative or supervisory staff, including any principal may be suspended or dismissed at any time during the term of the contract; however, the charges against him or her must be based on immorality, misconduct in office, incompetency, gross insubordination, 24. willful neglect of duty, drunkenness, or being convicted or found guilty of, or entering a plea of guilty, regardless of adjudication of guilt, any crime involving moral turpitude, as these terms are defined by rule of the State Board of Education. A. Those charges are defined as follows: “Immorality” means conduct that is inconsistent with the standards of public conscience and good morals. It is conduct that brings the individual concerned or the education profession into public disgrace or disrespect and impairs the individual's service in the community. “Misconduct in Office” means one or more of the following: 1. A violation of the Code of Ethics of the Education Profession in Florida as adopted in Rule 6B-1.001, F.A.C.; 2. A violation of the Principles of Professional Conduct for the Education Profession in Florida as adopted in Rule 6B-1.006, F.A.C.; 3. A violation of the adopted school board rules; 4, Behavior that disrupts the student's learning environment; or 5. Behavior that reduces the teacher's ability or her or her colleagues' ability to effectively perform duties. “Incompetency” means the inability, failure or lack of fitness to discharge the required duty as a result of inefficiency or incapacity. 1. “Inefficiency” means one or more of the following: a. Failure to perform duties prescribed by law; b. Failure to communicate appropriately with and relate to students; c. Failure to communicate appropriately with and relate to colleagues, administrators, subordinates, or parents; d. Disorganization of her or her classroom to such an extent that the health, safety or welfare of the students is diminished; or e. Excessive absences or tardiness. 2. “Incapacity” means one or more of the following: a. Lack of emotional stability; 8 25. 26. 27. 28. 29. b. Lack of adequate physical ability; c. Lack of general educational background; or d. Lack of adequate command of her or her area of specialization. D. “Gross insubordination” means the intentional refusal to obey a direct order, reasonable in nature, and given by and with proper authority; misfeasance, . or malfeasance as to involve failure in the performance of the required duties. E. “Willful neglect of duty” means intentional or reckless failure to carry out required duties. FE. “Crimes involving moral turpitude.” A. IMMORALITY Respondent’s actions constitute just cause to suspend his employment without pay for a period of five (5) days. B. MISCONDUCT IN OFFICE Respondent’s actions constitute misconduct in office. c. INCOMPETENCY Respondent’s actions constitute incompetency. D. WILLFUL NEGLECT OF DUTY Respondent’s actions constitute willful neglect of duty E. CODE OF ETHICS Respondent’s actions constitute a violation of Rule 6A- 10.081 of the Florida Administrative Code, defining Principles of Professional Conduct for the Education Profession in Florida. DEMAND FOR RELIEF WHEREFORE, based upon the foregoing, Petitioner, Robert W. Runcie, Superintendent of Schools, recommends that the School Board suspend the Respondent, John LaCasse without pay for five (5) days based upon the foregoing facts and legal authority. ; jt EXECUTED this | — day of ber, 2016. ROBERT W. RUNCIE, Superintendent of Schools, Broward County Respectfully submitted: Douglas G. Griffin, Esq. Assistant General Counsel NOTICE If you wish to contest the charges, you must, within 15 days after receipt of the written notice, submit a written request for a hearing to Robert W. Runcie, Superintendent, Broward County School District, 600 374 Ave., Ft. Lauderdale, FL, 33301. Lf timely requested, such hearing shall be conducted by an administrative law judge assigned by the Division of Administrative Hearings of the Department of Management Services. The hearing shall be conducted within 60 days after receipt of 10 the written appeal in accordance with chapter 120, Florida Statutes. FAILURE TO TIMELY REQUEST A HEARING WILL RESULT IN A WAIVER OF THE RIGHT TO CONTEST THE CHARGES. IF YOU WANT TO HIRE AN ATTORNEY, YOU HAVE THE RIGHT TO BE REPRESENTED BY AN ATTORNEY IN THIS MATTER. 11 THIS HAS BEEN ISSUED AT THE REQUEST OF: Douglas G. Griffin (754) 321-2050 RECEIVED THIS NOTICE AND ADMINISTRATIVE COMPLAINT ON: — Mw: | i 2h, at/30 Ar Sonetock; _ m., and served the same on 1 20, at o'clock, __.m., by delivering a true copy thereof (together with the fee for one day's attendance and the mileage allowed by law*) —= to:\R - Jolin (aCas5 COMPLETE IF SERVED BY SWORN LAW ENFORCEMENT OFFICER Mats , 20/6, ar (350 rs 7 x o' glock, ——-™-—- wy: O71 Kode MO nities LAs + 5 rae to:

Docket for Case No: 16-007492