L3-136Y 4 STATE OF FLORIDA EDUCATION PRACTICES COMMISSION TOM GALLAGHER, as Commissioner of Education, Petitioner, YS. . CASE NO. 990-1103-M ROBERT COOPER, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, TOM GALLAGHER, as Commissioner of Edu zation, files this Administrative Complaint against Robert Cooper. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educator’s certificate pursuant to Sections 231.262 ar d 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 fo-th in Sections 231.262(6) and 231.28(1), Florida Statutes. The Petitioner alleges: JURISDICTION 1. The Respondent holds Florida Educator’s Certificate 624181, covering the area of Music, which is valid through June 30, 2001. 2. At all times pertinent hereto, the Respondent was employed as a Music teacher at Eagle Ridge Middle School, in the Broward County School District. MATERIAL ALLEGATIONS 3. During the 1998-1999 school year, Respondent acted inappropriately toward female students when he touched their clothing in an overly familiar way, removed a hair ribbon from a student’s hair and let her hair down without permission because he said he “wanted to see what she looked like in the morning.” Respondent also allowed female students to sit on his lap, hugged female students in a close embrace and favored female students in class as shown by the fact that he interacted with the females almost to the exclusion of male students. . Robert Cooper 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)(), Florida Statutes, in that Respondent has violated the Prinziples 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 protect 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. COUNT 4: The allegations of misconduct set forth her 2in are in violation of Rule 6B- 1.006(3)(g), Florida Administrative Code, in that Respondent has harassed or discriminated against a student on the basis of race, color, religion, sex, age, national or ethnic origin, political beliefs, marital status, handicapping condition, or social and family background and has failed to make reasonable effort to assure that each student is protected from harassment or discrimination. WHEREFORE, the Petitioner recommends that the Educat:on Practices Commission impose an appropriate penalty pursuant to the authority provided in Sec:ions 231.262(6) and 231.28(1), - Florida Statutes, which penalty may include a reprimand, probat on, restriction of the authorized scope of practice, administrative fine, suspension of the teaching certificate not to exceed three years, ~<) syérmianent 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 6 2 day of __, 2000. 7 == oy ~ Coramissioner of Education, State of Florida TER re rome ren

Docket for Case No: 02-001364PL