an U STATE OF FLORIDA EDUCATION PRACTICES COMMISSION TOM GALLAGHER, as Commissioner of Education, Petitioner, vs. CASE NO. 989-2352-M CHARLES J. BOLDWYN, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, TOM GALLAGHER, as Commissioner of Education, files this Administrative Complaint against Charles J. Boldwyn. 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 537677, covering the areas of Chemistry, Physics and General Science, which is valid through June 30, 2000. 2. At all times pertinent hereto, the Respondent was employed as a Science teacher at Miami Killian Senior High School, in the Dade County School District. MATERIAL ALLEGATIONS 3. During October 1998, Respondent acted in an inappropriate, unprofessional manner when he made loud threats against his school principal, verbally threatened the school principal in person, used racial slurs referring to his principal, commented to other staff members sufficient to cause them to fear for their safety and stated to other staff members that he was going to “do something big, get a lot of press coverage and make it go boom." 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. . Vo. wv Charles J. Boldwyn 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)(), 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(4)(b), Florida Administrative Code, in that Respondent has intentionally distorted or misrepresented facts concerning an educational matter in direct or indirect public expression. COUNT 5: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(5)(d), Florida Administrative Code, in that Respondent has engaged in harassment or discriminatory conduct which unreasonably interfered with an individual’s performance of professional or work responsibilities or with the orderly processes of education or which created a hostile, intimidating, abusive, offensive, or oppressive environment; and further, failed to make reasonable effort to assure that each individual was protected from such harassment or discrimination. COUNT 6: The allegations of misconduct set forth herein are in violation of Rule 6B- 1,006(5)(£), Florida Administrative Code, in that Respondent has used coercive means or promised special treatment to influence professional judgment of colleagues. 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. W EXECUTED on this_ 4 “day of Fibsen z= 2000. =<—O bow TOM GALL as Commissioner of Education, State of Florida

Docket for Case No: 00-003720PL