STATE OF FLORIDA OEE pm ga EDUCATION PRACTICES COMMISSION, a ce 2 AUG ~9 AN Vj I}: 23 Joh TOM GALLAGHER, as Commissioner of Education, Petitioner, vs. CASE NO. 990-1876-C BILLY JACKSON, Respondent. My 4 ADMINISTRATIVE PLAINT Petitioner, Tom Gallagher, as Commissioner ‘of Education, files this Administrative Complaint against Billy Jackson. 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 625149, covering the areas of Physical Education.and Driver Education, which is valid through June 30, 2002. 2. At all times pertinent hereto, the Respondent was employed as a Physical Education teacher at Brandon High School, in the Hillsborough County School District. MATERIAL ALLEGATIONS 3. On or about April 30, 2000, Respondent battered his wife by striking her in the face with a closed fist. Respondent was arrested and charged with Battery (Domestic). On or about July 10, 2000, the case was closed after Respondent entered into a Pre-Trail Diversion Program. Billy Jackson Administrative Complaint 2 of 2 STATUTE VIOLATION COUNT 1: The Respondent is in violation of Section 231.28(1)(c), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving mora! turpitude. COUNT 2: The Respondent is in violation of Section 23 1.28(1)(f), Florida Statutes, in that Respondent has been found guilty of personal conduct which seriously reduces his effectiveness as an employec of the school board. 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 hercof by reference. EXECUTED on this_2.1 ££ day of Horne , 2000. — (em TOM GALL. R, as Commissioner of Education State of Florida

Docket for Case No: 02-003135PL