STATE OF FLORIDA EDUCATION PRACTICES COMMISSION TDM GALLAGHER, as Commissioner of Education, Petitioner, v. : CASE NO. 989-1955-C RDBERT M. DUPLER, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, TOM GALLAGHER, as Commissioner of Education, files this Administrative Cbmplaint against Robert M. Dupler. The.Petitioner seeks thé appropriate disciplinary sanction of the Respondent’s educator’s certificate pursuant to Sections 231.262 and 231.28, Florida Statutes, aid pursuant to Rule 6B-1.006, Florida Administrative Code, Principles of Professional Conduct for the Education Profession in Florida, said sanctions specifically set forth in Sections 231.262(6) and 23 1.28(1), Florida Statutes. The Petitioner alleges: JURISDICTION 1, The Respondent holds Florida Educator’s Certificate 647247, covering the area of physical education , which is valid through June 30, 2003. 2. Atall times pertinent hereto, the Respondent was employed as a physical education tdacher at Lecanto High School, in the Citrus County School District. MATERIAL ALLEGATIONS 3. On or about January 22, 1999, Respondent was involved in a domestic dispute, during hich he manhandled his wife by grabbing her hand, and took away her house keys. He forced his ay into the house, and while there knocked his wife over the bed, and caused her to strike her head a dresser. Respondent left the house with his children. Respondent was arrested, and charged ith two counts of Domestic Battery. After completing a pre-trail program the charges against lespondent were dropped. Robert M. Dupler Administrative Complaint Page 2 of 2 STATUTORY VIOLATIONS COUNT 1: The allegations of misconduct set forth herein are in violation of Section 31.28(1)(c), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude. COUNT 2: The allegations of misconduct set forth herein are in violation of Section 31,28(1)(f), Florida Statutes, in that Respondent, upon investigation, has been found guilty of lersonal conduct which seriously reduces his effectiveness as an employee of the school board. WHEREFORE, the Petitioner recommends that the Education Practices Commission impose In appropriate penalty pursuant to the authority provided in Sections 231.262(6) and 231.28(1), lorida Statutes, which penalty may include a reprimand, probation, restriction of the authorized pe of practice, administrative fine, suspension of the teaching certificate not to exceed three years, ermanent revocation of the teaching certificate, or combination thereof, for the reasons set forth erein, and in accordance with the Explanation and Election of Rights forms which are attached ereto and made a part hereof by reference. tu XECUTED on this_) ‘~~ day of phe 1999, —_—_—_ L o~ ° TOM GALLAGHER! as Commissioner of Education, State of Florida On U Florida Department of Educaticti: Department of Education MEMORANDUM CHARLES WHITELOCK, Attorney FROM: CAROLYN SATTERWHITE, Paralegal S~ Robert Dupler PPS Case no. 989-1955-C : EPC Case no. 99-0296-RA DATE: January 4, 2000 The above referenced matter has been assigned to you for handling. Since settlement negotiations have failed, this matter will be sent for formal hearing. Please find the file attached. If you have any questions, please call. cc: Anne Martone Jerry Whitmore Kathleen Richards 4

Docket for Case No: 00-000215