Fi _ STATE OF FLORIDA no ° ofA B EDUCATION PRACTICES COMMISSION “°F ~5 Py : % LV, , es It ; ae ww . be AG; Une OH OF CHARLIE CRIST, as Weg rpRAry, Commissioner of Education, ERG ec Petitioner, . O a —-Y3& A ‘4 x vs. ) CASE NO. 001-0628-V IVY K. DOMINGUEZ, Respondent. ADMINISTRATIVE COMPLAINT - Petitioner, CHARLIE CRIST, as Commissioner of Education, files this Administrative Complaint against Ivy K, Dominguez. 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 441764, covering the areas of elementary education, mentally handicapped education, and physically handicapped education, -which is valid through June 30, 2003. 2. At all times pertinent hereto, the Respondent was employed as an exceptional student education teacher at Homestead Senior High School, it the Miami-Dade County School District. Ivy K. Dominguez Administrative Complaint % Page 2 of 3 MATERIAL ALLEGATION3 Students with rulers , folders, Slapping students on the arm and in the face, and using offensive language. Respondent failed to maintain order in her class and allowed students to leave her class without permission and without Teporting their absences appropriately to school authorities. 4, On or about September 21, 2000, was in possession of a controlled substance Marijuana. Respondent was tested in a “Reasonable suspicion drug screen” and was found to have recently used marijuana. ‘ TAT YV TONS COUNT 1: The allegations of misconduct set forth ‘erein 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 ‘1erein are in violation of Section 231.2615(1)(f), Florida Statutes, in that Respondent, upon investigation, has been found guilty of personal conduct which seriously reduces her effectiveness as an employee of the school board, COUNT 3: The allegations of misconduct set forth Jerein 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 State Board of Education. RULE VIOLATIONS COUNT 4: 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: 5: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(e), Florida Administrative Code, in that Respondent tas intentionally exposed a student to unnecessary embarrassment or disparagement. Ivy K. Dominguez Administrative Complaint.; Page 3 of 3 ” 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 Rights forms which are attached hereto and made a part hereof by reference: EXECUTED on this / day of feb : __» 2001. CEARLIE CRIST, as Commissioner of Education, State of Florida

Docket for Case No: 02-004364PL