STATE OF FLORIDA _ if fp va f CHARLIE CRIST, as Commissioner of Education, Petitioner, vs. , CASE NO. 012-1733-Q ROGER K. ROBERTS, JR.,, 03-6563 fL Respondent. / ADMINISTRATIVE COMPLAINT. Petitioner, Charlie Crist, as Commissioner of Education, files this Administrative Complaint against ROGER K. ROBERTS, JR. 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 619621, covering the areas of Biology and Chemistry, which is valid through June 30, 2003. 2. At all times pertinent hereto, the Respondent was employed as a Science teacher at East Bay High School in the Hillsborough County School District. MATERIAL ALLEGATIONS 4 3. On or about March 13, 2000, the Education Practices Commission (EPC) issued a Final Order accepting a Settlement Agreement which included the terms of the Respondent’s being placed on 3 years of probation to commence on the date of the Final Order and that he violate no law during the period of his probation. The charges for which the Respondent was placed on probation included three DUI charges spanning from 1991-1996. On or about January 13, 2002, the Respondent exposed his penis in a public place and/or in a vulgar or indecent manner. While sitting ina vehicle with the door open, the Respondent pulled his penis out of his pants and pulled on it in the presence of an officer whom he was conversing with and a female victim. The Respondent was also intoxicated. He was arrested and charged with Exposure of Sexual Organs. On or about ROGER K. ROBERTS, JR. Administrative Complaint Page 2 of 3 February 28, 2002, the superintendent of the Hillsborough County School Board suspended the Respondent with pay. On or about March 13, 2002, the school board suspended the Respondent without pay. With regards to the charge, the Respondent completed a diversion program and, on or about March 20, 2002, and the State Attorney’s Office nolle prosed the charge. 4, On or about January 13, 2002, when the Respondent exposed himself, the Respondent held a valid Florida Educator’s Certificate and was employed in a teaching position requiring such certificate with the Hillsborough County School District. Employed as such, the Respondent was still on EPC probation at the time. By exposing himself in violation of section 800.03, Florida Statutes and, thus, violating the term of his probation that the Respondent “violate no law,” the Respondent violated his EPC probation. 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 whicki seriously reduces his 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 the State Board of Education. RULE VIOLATIONS COUNT 4: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(5)(p), Florida Administrative Code, in that Respondent has failed to comply with the conditions of an order of the Education Practices Commission imposing probation, imposing a fine, or restricting the authorized scope of practice. ROGER K. ROBERTS, JR. 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(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 BO dayof_ZJul , 2002. , Cutt. Charlie Crist, as Commissioner of Education, State of Florida

Docket for Case No: 03-000562PL