STATE OF FLORIDA Foy, Oe EDUCATION PRACTICES COMMISSION ey CHARLIE CRIST, as Commissioner of Education, Petitioner, . 03-01 KO PL vs. CASE NO. 012-1447-R SHIRLEY A. BAXTER, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Charlie Crist, as Commissioner of Education, files this Administrative Complaint against SHIRLEY A. BAXTER. 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(7) and 231.2615(1), Florida Statutes. The Petitioner alleges: JURISDICTION 1. The Respondent holds Florida Educator’s Certificate 836749, covering the area of Psychology, which is valid through June 30, 2003. 2. At all times pertinent hereto, the Respondent was employed as a Substitute Teacher at Ribault Middle School in the Duval County School District. MATERIAL ALLEGATIONS 3. On or about September 28, 2001, Respondent engaged in inappropriate conduct with G.T., date of birth April 29, 1988. After G.T. touched or patted Respondent on her hair, Respondent got up out of her chair, chased G.T., and grabbed her by the hair. A struggle ensued with both Respondent and G.T. falling to the floor swinging at and striking one another. On or about October 19, 2001, the school district terminated Respondent. SHIRLEY A. BAXTER 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)(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 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 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 leaming 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 has intentionally exposed a student to unnecessary embarrassment or disparagement. 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 ,3 0 day of Su My , 2002. Charlie Crist, as Commissioner of Education, State of Florida Richards, Kathleen From: Odom, Tamara Sent: Tuesday, January 14, 2003 10:09 AM To: Richards, Kathleen Ce: Whaley, Richard; Odom, Tamara Subject: Shirley Baxter PPS No. 012-1447-R Please schedule Ms. Baxter for a formal hearing at DOAH. Ron Weaver will represent the Dept. Thanks. Tamara Ordon, Paralegal Professional Practices Services nie of the General Counsel 922-7095 per ; YY un felt Ba pa or asst 03

Docket for Case No: 03-000180PL