STATE OF FLORIDA fn EDUCATION PRACTICES COMMISSION ao.) 19 ~ Ay, . Me py CHARLIE CRIST, as Commissioner of Education, Petitioner, Vs. CASE NO. 001-1108-M BARRY TRAYNOR, Respondent. / ADMINISTRATIVE COMPLAINT. Petitioner, Charlie Crist, as Commissioner of Education, files this Administrative Complaint against Barry Traynor. The Petitioner seeks the appropriate disciplinary sanction of _the Respondent’s educator’s certificate pursuant to Sections 231.262 and 231.2615, 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 231.2615(1), Florida Statutes. The Petitioner alleges: JURISDICTION 1. The Respondent holds Florida Educator’s Certificate 477398, covering the areas of Administration/Supervision, Elementary Education, Mathematics and General Science which is valid through June 30, 2005. 2. At all times pertinent hereto, the Respondent was employed as a Science Teacher at William Dandy Middle School in the Broward County School District. MATERIAL ALLEGATIONS . 3. During the fall of 2000, Respondent sexually harassed female students. The harassment included touching their breasts and/or buttocks and licking his tongue toward them. On or about November 9, 2000, Respondent was reassigned pending an investigation. Although on or about January 10, 2001, school district officials recommend Respondent for termination, he later received a letter of reprimand and was returned to the classroom for the 2001-2002 school year. Barry Traynor Administrative Complaint Page 2 of 2 STATUTORY VIOLATIONS COUNT 1: The allegations of misconduct set forth herein are in violation of Section 231.2615(1)(c), Florida Statutes, in that Respondent has been guilty of gross immorality or an act * involving moral turpitude. COUNT 2: The allegations of misconduct set forth herein are in violation of Section 231.2615(1)(i), Florida Statutes, in that Respondent has violated the Principles of Professional Conduétt for the Education Profession in Florida prescribed by State Board of Education. RULE VIOLATIONS COUNT 3: 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 4: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(¢), Florida Administrative Code, in that Respondent has intentionally exposed a student to unnecessary embarrassment or disparagement. COUNT 5: 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. WHEREFORE, the Petitioner recommends that the Education Practices Commission impose an appropriate penalty pursuant to the authority provided in Sections 231. 262(6) and 231.2615(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 Ri ghts forms which are attached hereto and made a part hereof by reference. EXECUTED on this / 3 day of Feb fear , 2002. Charlie Crist, as Commissioner of Education, State of Florida

Docket for Case No: 02-003534PL