STATE OF FLORIDA d EDUCATION PRACTICES COMMISSION N ci aneae TOM GALLAGHER, as 4 DMs Commissioner of Education, i HES : Petitioner, vs CASE NO. 990-1466-V 5 STACEY JONES, ; . Respondent. ADMINISTRATIVE COMPLAINT ae ae Florida Statutes. The Petitioner alleges: URISDICTION He lie i a ‘ Experience Programs, which is valid through June 30, 2003. D. McMillan Middle School, in the Dade County School District. MATERIAL ALLEGATION: 3. During the 1998-1999 school year, Respondent acted inappropriately toward female employees, in that he grabbed the buttocks of a Ms. I. Hernandez, and in doing so made inappropriate remarks and at other times brushed against her breasts and made numerous sexually suggestive remarks toward her creating an oppressive working environment for her. Respondent also suggested that he and Ms. Hernandez have sex and asked her if he could touch her breasts, while in the presence ‘ of other staff members. Respondent also acted inappropriately when he made off color sexual remarks, 4 told sexual jokes which made employees uncomfortable and made sexually suggestive remarks to other ! female staff similar to those made to Ms. Hernandez. Petitioner, Tom Gallagher, as Commissioner of Education, files this Administrative Complaint against Stacey Jones. 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), 1, The Respondent holds-Florida Educator’s Certificate 146417, covering the areas of Administrator of Adult Education, School Principal, Social Science and Teacher Coordinator of Work 2. At all times pertinent hereto, the Respondent was employed as a Principal at Howard eer eee i Ae ee a i a i a A ae ee kde CoRR ER care eee Stacey Jones Administrative Complaint 2 of 2 STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 23 l .28(1)(c), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude. COUNT 2: The Respondent is in violation of Section 231.28(1)(f), Florida Statutes, in that Respondent has been found guilty of personal conduct which seriously reduces his effectiveness as an employee of the school board. COUNT 3: The Respondent is in violation of Section 231.28(1)(i), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession prescribed by State Board of Education rules. RULE VIOLATION: COUNT 4: 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 5: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(5)(f), Florida Administrative Code, in that Respondent has used coercive means or promised special treatment to influence professional judgments 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. te EXECUTED on this I4™ day of Bree. be , 2000. * Commissioner of Education State of Florida ower TR eRe ore ore

Docket for Case No: 02-000303PL