a, May “Hee j ~~" STATE OF FLORIDA _ EDUCATION PRACTICES COMMISSION a) TOM GALLAGHER, as Commissioner of Education, Petitioner, . 0 On 4 ¢/ VS. , CASE NO. 990--136-C TIMOTHY S. FALLS, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, TOM GALLAGHER, as Commissioner of Education, files this Administrative Complaint against Timothy S. Falls. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educator’s certificate pursuant to Sections 231.262 and 231.28, Florida Statutes, and 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” 231.28(1), Florida Statutes. : : .- The Petitioner alleges: JURISDICTION 1 . The Respondent holds Florida Educator's Certificate 729330, covering the areas of Social Science, which is valid through June 30, 2001. 3 Ral times pertinent hereto, the Respondent was employed as a Social Studies teacher at Palm Harbor University High School, in the Pinellas County School District. MATERIAL ALLEGATIONS . 3. Onor about April 23, 1999, Respondent entered into inappropriate discussions with his class. In discussing the bombing and murders at Columbine High School, Respondent drew a pipe bomb for his students, explained the various parts and then discussed the proper placement of such a device at Palm Harbor University High School where it would do the most damage and injury. On or about June 15, 1999, Respondent was recommended for a,10 day suspension without pay. Timothy S. Falls Administrative Complaint Page 2 of 2 STATUTORY VIOLATIONS COUNT 1: The allegations of misconduct set forth herein are in violation of Section 231.28(1)(i), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession in Florida prescribed by State Board of Education. RULE VIOLATIONS COUNT 2: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(a), Florida Administrative Code, in that Respondent has failed to make reasonable effort to pfotect the student from conditions harmful to learning and/or to the student’s mental health and/or physical safety. : . COUNT 3: The allegations of misconduct set forth herein are in violation of Rule 6B- 1,006(3)(e), Florida Administrative Code, in that Respondent has intentionally exposed a student to unnecessary embarrassment or disparagement. WHEREFORE, the Petitioner recommends that the Education Practices Commission impose an appropriate penalty pursuant to the authority provided in Sections 231.262(6) and 231.28(1), Florida Statutes, which penalty may include a reprimand, probation, restriction of the authorized scope of practice, administrative fine, suspension of the teaching certificate not to exceed three years, “permanent revocation of the teaching certificate, or combination thereof, for the reasons set forth herein, and in accordance with the Explanation and Election of Rights forms which are attached hereto and made a.part hereof by reference. : oe EXECUTED on this 22“ day of _ eb 1999. fy f Rj as "TOM GALIAG! i ducation, Commissioner State of Florida

Docket for Case No: 00-000387