Y VU FILED STATE OF FLORIDA EDUCATION PRACTICES COMMISSION 00 JUL ~6 PH IF 9 DIVISION oF : : : ADMIE TOM GALLAGHER, as . eae IVE Commissioner of Education, Petitioner, . : OO-2 7 b & fi ye vs. CASE NO. 990-0334-C HENRY DUNN, JR., Respondent. _ ADMINISTRATIVE COMPLAINT Petitioner, TOM GALLAGHER, as Commissioner of Education, files this Administrative Complaint against, Henry Dunn, Jr.. 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 i 1. The Respondent holds Florida Educator’s Certificate 553672, covering the areas of History and Guidance and Counseling, which is valid through June 30, 2000. 2. At all times pertinent hereto, the Respondent was employed as a Social Studies teacher at - Jefferson High School, in the Hillsborough County School District. MATERIAL ALLEGATIONS 3. During April or May 1999, Respondent gave his students the answers for the World History exam. By doing so he invalidated the test and violated test security arrangements. Respondent ven instructed his students to get a few of the questions wrong in order not-to arouse suspicion. On or “about June 1, 1999, Respondent resigned with the Hillsborough County School District. STATUTORY VIOLATIONS COUNT 1: The allegations of misconduct set forth herein are in violation of Section 231.28(1)(c), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude. ee ewe Sar Senne 3 | Le E D . Henry Dunn, Jr. 60 JUL ~6 PH ki | ) Administrative Complaint Page 2 of 2 DIVISION IVISION OF COUNT 2: The allegations of ffishO8duA Bey Fforth herein are in violation of Section 231.28(1)(f), Florida Statutes, in that ResponddatAuialtiivestigation, has been found guilty of personal conduct which seriously reduces his effectiveness as an employee of the school board. ; COUNT “3: The allegations of misconduct set forth herein are in violation of Section 231.28(1)(), 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 4: 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 protect the student from conditions harmful to learning and/or to the student’s mental health and/or physical safety. COUNT 5: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(d), Florida Administrative Code, in that Respondent has intentionally suppressed or distorted subject matter relevant to a student’s academic program. COUNT 6: 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. - COUNT 7: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(5)(a), Florida Administrative Code, in that Respondent has failed to maintain honesty in all professional dealings. - 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. EXECUTED on this _@ ‘—_ day of , 2000. “Con TOM G: GHER, as Commissioner of Education, State of Florida

Docket for Case No: 00-002768PL