STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner ef Education, Petitioner, vs. CASE NO. 134-2850 ROBERT BH. KONNOVITCH, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against ROBERT H. KONNOVITCH. 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 899447, covering the areas of Health, Physical Education and Driver Education, which is valid through June 30, 2020, 2. At all times pertinent hereto, the Respondent was employed as a Physical Education Teacher at Riverglades Elementary School in the Broward County School District. MATERIAL ALLEGATIONS 3. During the 2013/2014 school year, Respondent behaved inappropriately in the classroom in that he yelled at students, used profanity during class, embarrassed students and physically threatened students. Examples of Respondent’s conduct include but are not limited to, a) Onor about January 10, 2014, Respondent grabbed S.W., a ten year old, female student, by the arm and yelled in her ear, “Shut up!” or words to that effect. ROBERT H. RONNOVITCH Administrative Complaint Page 2 of 3 b) During the 2013/2014 school year, Respondent repeatedly called J.G., a fifth grade, male student of Hispanic descent, ‘Miguel,’ even though this was not J.G."s name and after 1G, repeatedly asked him not to, embarrassing J.G. and resulting in students mimicking Respondent’s behavior. c) Respondent called students derogatory names such as stupid and idiot or words to that effect. d) On or about February 26, 2014, Respondent called C.B., a fifth grade, male student, a loser in front of C.B.’s classmates. e) Respondent used profanity including but not limited to; fuck, shit, and God damn, in the classroom. 4. On or about April 22, 2015, Respondent’s Superintendent recommended Respondent’s suspension and termination. Both actions were upheld by Recommended Orders from Administrative Law Judges through the Division of Administrative Hearings (DOAH). The Petitioner charges: STATUTE VIOLATIONS COUNT i: 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 2; The Respondent is in violation of section 1012.795(1)), 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 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. COUNT 4: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081G)e), Florida Administrative Code, in that Respondent has intentionally exposed a student to unnecessary embarrassment or disparagement. (SIGNATURE ON FOLLOWING PAGE} ROBERT H. KONNOVITCH 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 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 (3™ day of IVyiwoin , 2016. Commissioner of Education State of Florida

Docket for Case No: 17-000501PL