Ce ) “ILED STATE OF FLORIDA EDUCATION PRACTICES COMMISSEOWUL -6 PH I: 16 TOM GALLAGHER, as A OHAISTEA ve Commissioner of Education, Petitioner, OO Br vs. . CASE NO. 990-0186-C BRENT C. BUCHANAN, Respondent. ‘ADMINISTRATIVE COMPLAINT Petitioner, TOM GALLAGHER, as Commissioner of Education, files this Administrative Complaint against Brent C. Buchanan. 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 707978, covering the area of Social Sciences, which is valid through June 30, 2002. 2. At all times pertinent hereto, the Respondent was employed as a Social Studies teacher at Eau Gallie High School, in the Brevard County School District. MATERIAL ALLEGATIONS 3. On or about October 1998, Respondent who was the school’s basketball coach paid a male student player, R.P., money to expose his penis to him. On or about May 24, 1999, Respondent resigned his position with the 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. Brent C. Buchanan Administrative Complaint Page 2 of 2 COUNT 2: The allegations of misconduct set forth herein are in violation of Section 231.28(1)(f), Florida Statutes, in that Respondent, upon investigation, 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)(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 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)(e), Florida Administrative Code, in that Respondent has intentionally exposed a student to unnecessary embarrassment or disparagement. COUNT 6: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(h), Florida Administrative Code, in that Respondent has exploited a relationship with a student for personal gain or advantage. COUNT 7: The allegations of misconduct set forth herein are in violation of Rule 6B- 1,006(4)(e), Florida Administrative Code, in that Respondent has offered gratuity, gift, or favor to obtain special advantages. 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. 4 EXECUTED on this_¢ — day of 2000, _—— Lone TOM G. GHER, as Commissioner of Education, State of Florida

Docket for Case No: 00-002774PL