LA PDIS PL STATE OF FLORIDA EDUCATION PRACTICES COMMISSION CHARLIE CRIST, as Commissioner of Education, Petitioner, vs. CASE NO. 012-0790-V FRANKLIN WALTERS, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Charlie Crist, as Commissioner of Education, files this Administrative Complaint against FRANKLIN WALTERS. 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 404912, covering the area of Social Science, which is valid through June 30, 2002. 2. At all times pertinent hereto, the Respondent was employed as a Social Science teacher at Miami Palmetto High School in the Miami-Dade County Schoo} District. MATERIAL ALLEGATIONS 3. Between the beginning of the 2001-2002 school year and February 8, 2002, inclusive. the Respondent made inappropriate comments which have subjected his students to conditions which were harmful to their mental health. The Respondent has discussed topics in front of his students along the lines of: 1) the distance one can be away from a bomb and still be incinerated; 2) the percentage of the students who would be dead by the time they reached different ages; 3) the ease with which an entire people could be obliterated; 4) physical changes in a corpse that occur in a person who has just died; 5) methods the Romans used to kill babies; and/or 6) methods terrorists could use to cause mass destruction. FRANKLIN WALTERS Administrative Complaint Page 2 of 3 4. Specifically, on or about September 17, 2001, the Respondent described ways in which terrorists could cause mass destruction in the Miami area. He then gave the students an assignment to put themselves in the mind set of a terrorist and write an essay about how they could cause mass destruction in Miami area. On or about September 19, 2001, the Respondent admitted that he had given the students the assignment. 5. On or about September 24, 2001, the Respondent was placed on temporary duty at the Region V office in Miami-Dade. On or about October 9, 2001, a Conference for the Record was held and the Respondent was given a referral to the Employee Assistance Program by his principal. On or about October 10, 2001, the Respondent returned to his teaching position. 6. During the first semester of the 2001-2002 school year, the Respondent discriminated or reverse-discriminated against students on the basis of their race and/or economic (social) background. In doing so, he failed to make a reasonable effort to protect his students from such discrimination. On or about January 24, 2002, the Respondent informed his psychology class that, throughout the first semester of the 2001-2002 school year, he had taken the students’ race and/or economic backgrounds into consideration when assigning their grades in order to “Jevel the playing field,” or words to that effect, for those who were disadvantaged. 7. On or about March 1, 2002, the Respondent again made inappropriate comments in the classroom which subjected his students to conditions harmful to their mental health. He described incidents along the lines of his having watched a headhunter sever a man’s head with his long, razor-sharp fingernails and/or having eaten stew the headhunters made in which a hand, either belonging to a human or a monkey, was found. When the student reported this incident, she stated that the Respondent typically made inappropriate comments of this nature to his students nine class days out of ten. 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 Conduct for the Education Profession in Florida prescribed by the State Board of Education. FRANKLIN WALTERS Administrative Complaint Page 3 of 3 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 leaming 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)(e), 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)(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 Education Practices Commission impose an appropriate penalty pursuant to the authority provided in Sections 231.262(7) 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 Rights forms which are attached hereto and made a part hereof by reference. EXECUTED on this i) day of in , 2002. Charlie Crist, as Commissioner of Education, State of Florida

Docket for Case No: 02-003945PL