BEFORE THE SCHOOL BOARD OF MARION COUNTY, FLORIDA CASE NO. 19-013 DR. HEIDI MAIER, Superintendent of Schools, Petitioner, vs. BRANDI STEPHENS, an employee of the School Board of Marion County, Respondent ADMINISTRATIVE COMPLAINT Petitioner, Dr. Heidi Maier, Superintendent of Schools ("Petitioner"), files this Administrative Complaint against Brandi Stephens ("Respondent"), an employee of the School Board of Marion County (hereinafter referred to as SBMC), and alleges as follows: 1. Respondent is an employee and is currently employed as a Special Needs Paraprofessional at Sparr Elementary School. 2. Petitioner was notified of a complaint regarding Respondent on March 15, 2019 alleging that Respondent on March 14, 2019, failed to provide adequate supervision to a student, which subjected the student to potential serious injury. 3. An investigation regarding this incident was commenced on March 15, 2019, and concluded on March 19, 2019 by Dawana Gary, Director of Equity Assurance. 4. The investigation revealed that the student attended Sparr Elementary and was an 8-year-old third grader, who received Exceptional Student Education (ESE) services. Video evidence was obtained showing the student was repeatedly banging his head on the cabinet door approximately 30 times and hitting his fist/hand approximately 1 32 times. Three adults, including Respondent, were present and observed this behavior. One of the three video recorded some of this behavior; but no one took any steps to stop the student from engaging in the behavior, which clearly subjected the student to the risk of serious harm and injury. De Respondent failed to take action to protect the student from serious injury, thereby seriously jeopardizing the health and safety of the student. 6. The evidence shows that the Respondent has failed the student in an egregious manner and failed to provide adequate supervision to the student in her care. The Respondent further failed to protect the student from conditions harmful to learning and/ or the student’s mental health and safety and failed to provide a learning environment for student success. ds Respondent’s actions violated the Principles of Professional Conduct for Education Profession, (FAC 6A-10.081), by failing to make reasonable efforts to protect the student from conditions harmful to learning and/ or to the student’s mental and/ or physical health and/ or safety. The Principles of Professional Conduct for Education Profession, (FAC 6A-10.081), also provides that “the educators primary professional concern always be for the student and for the development of the student’s potential. The educator will therefore strive for professional growth and will seek to exercise the best professional judgment and integrity.” 8. Respondent’s actions are also in violation of the Districts’ Professional Ethics Policy 6.270, when she failed to make a reasonable effort to protect the student from conditions harmful to his physical health and safety. 9. Respondent’s conduct constitutes misconduct in office, willful neglect of duty, and just cause for discipline. 10. Moreover, the conduct described above constitutes just cause for termination of employment. Therefore, the Petitioner recommends that the School Board terminate Respondent’s employment. WHEREFORE, for the foregoing reasons, the undersigned Superintendent recommends that the Respondent be terminated, effective on the date the recommendation is acted upon by the SBMC. half vets Heidi Maier, Ed.D. Superintendent of Schools Dated: 25 March 201% COPIES FURNISHED | HEREBY CERTIFY that a true and exact copy of the foregoing “Amended Administrative Complaint” has been furnished this 25" day of March, 2019 as follows: BY EMAIL BY EMAIL Mark Levitt Paul Gibbs Attorney for Superintendent School Board Attorney Allen, Norton & Blue, P.A. The School Board of Marion County, Florida 1477 W. Fairbanks Ave., Ste. 100 512 S.E. Third Street Winter Park, Florida 32789 Ocala, FL 34471 mlevitt@anblaw.com paul.gibbs@marion.k12.fl.us BY HAND DELIVERY Ms. Brandi Stephens 2045 NW 42" St., Unit 5 Ocala, FL 34475 Marion County Public Schools 512 S.E. 3rd Street Ocala, Florida 34471 (352) 671-7544 By: Ce. L. Dba (ey Jaycee R. Oliver Executive Director of Employee Relations iG: Barbara Dobbins, Executive Director, Human Resources Gay Street, Principal, Sparr Elementary School Melissa Kinard, Director, Area 1 Lori Lively, Director, Risk Management Denise Vitale, Supervisor, Employment Services Rebecca Gideon, Supervisor, Payroll Melissa Threatt-Garner, Personnel Specialist, Employment Services

Docket for Case No: 19-002885