STATE OF FLORIDA EDUCATION PRACTICES COMMISSION CHARLIE CRIST, as Commissioner of Education, Re: 2g Petitioner, d wy QO xe) PL ys. CASE NO. 001-0499-M JAMES CAMPBELL, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Charlie Crist, as Commissioner of Education, files this Administrative Complaint against James Campbell. 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 749137, covering the area of Athletic Coaching, which is valid through June 30, 2002. 2. At all times pertinent hereto, the Respondent was employed as a Athletic Coach at Lake Mary High School in the Seminole County School District. JAMES CAMPBELL Administrative Complaint Page 2 of 2 MATERIAL ALLEGATIONS 3. On or about the weekend of July 4, 1999, Respondent engaged in inappropriate conduct with his nieces, Respondent placed his hand on the vagina of M.C., his 12-year-old niece, and inserted his fingers into her against her will. Later in the day, Respondent exposed his penis to M.C. and forced her to touch it and masturbate him. Respondent also inappropriately touched his niece, R.C., while both were on a couch and R.C, had a blanket over her. On or about September 27, 2000, Respondent was arrested and charged with Count 1, Sexual Battery and Count 2, Lewd and Lascivious Act. On or about September 28, 2000, the school district notified Respondent that his employment with the district was terminated effective immediately. On or about September 29, 2000, Respondent’s principal notified him that he was released from his coaching duties effective immediately. On or about November 28, 2000, the state attomey’s office filed no information in the case. 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 his effectiveness as an employee 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 231.2615(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 onthis_ / =? day of Fe brua CY _,2002. Charlie Crist, as Commissioner of Education, State of Florida JAMES H. CAMPBELL 16923 CR. 368 WINONA, TEXAS 75792 October 28, 2002 DEAR MR. CRIST, I WANT TO STRESS, I DID NOT DO WHAT I AM ACCUSED OF DOING. BECAUSE OF MY NEW JOB, I’M DO NOT PLAN TO CONTINUE COACHING OR RETURNING TO FLORIDA. I CAN NOT AFFORD THE EXPENSE OF MISSING WORK AND TRAVELING TO FLORIDA, HIRING A LAWYER AT THOUSANDS OF DOLLARS IS OUT OF THE QUESTION ALSO, ESPECIALLY SINCE I HAVE DONE NOTHING WRONG TO BEGIN WITH. I DO NOT WISH TO KEEP COACHING NOR MOVE BACK TO FLORIDA, SO 1 DON’T NEED A COACHING LICENSE. I AM NOT WILLING TO VOLUNTARILY GIVE RESPECTFULLY, J H. CAMPBELL NOISSINWO9 Q3AI303¥ LT h Ud €T AON 2002 S301L0VYd Nollvonag

Docket for Case No: 03-000394PL