STATE OF FLORIDA Oie EDUCATION PRACTICES COMMISSION SEP og Pit Ips 5 JIM HORNE, as . Commissioner of Education, Petitioner, vs. CASE NO. 001-1937-V SONDRA T. RAPHAN, Respondent. / __ ADMINISTRATIVE COMPLAINT Petitioner, Jim Horne, as Commissioner of Education, files this Administrative Complaint against SONDRA T. RAPHAN. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educator’s certificate pursuant to Sections 1012.795 and 1012.796, 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 1012.795(1) and 1012.795(7), Florida Statutes. The Petitioner alleges: JURISDICTION 1. The Respondent holds Florida Educator’s Certificate 472853, covering the areas of Elementary Education and English to Speakers of Other Languages (ESOL), which is valid through June 30, 2005. 2. At all times pertinent hereto, the Respondent was employed as an ESOL Teacher at Fulford Elementary School, in the Miami-Dade School District. MATERIAL ALLEGATIONS 3. On or about February 5, 2001, Respondent unnecessarily and intentionally pushed VE., a 9-year-old, female student, forcefully in the back. Respondent’s actions caused V.E. to stumble and fall into a desk. VE. was injured and started to cry. SONDRA T. RAPHAN Administrative Complaint 2 of 2 STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1){c), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude. COUNT2: The Respondentisin violation of Section 1012.795(1)(i); Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession prescribed by State Board of Education rules. 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 learning and/or to the student’s mental health and/or physical health and/or 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. WHEREFORE, the Petitioner recommends that the Education Practices Commission impose an appropriate penalty pursuant to the authority provided in Sections 1012.795(1) and 1012.796(7), 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 qe day of Mahe 2003. State of Florida

Docket for Case No: 03-003508PL