0 Fj STATE OF FLORIDA 0g Sép » nel EDUCATION PRACTICES COMMISSION “29 Py ! ily a AOMp pei . 6 LOT JIM HORNE, as ME. “PPh ve Commissioner of Education, . Petitioner, vs. CASE NO. 023-0103-B CHRISTIAN PIERRE-ANTOINE, ( | V( p UL Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Jim Horne, as Commissioner of Education, files this Administrative Complaint against CHRISTIAN PIERRE-ANTOINE. 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 1012.796(7), Florida Statutes. The Petitioner alleges: JURISDICTION 1. The Respondent holds Florida Educator’s Certificate 741483, covering the area of Computer Science, which was valid through June 30, 2004. 2. At all times pertinent hereto, the Respondent was employed as a Computer Science Teacher at Momingside Elementary School, in the Dade County School District. MATERIAL ALLEGATIONS 3. During the 2001-2002 school year, the Respondent engaged in inappropriate discipline of students, These incidents include, but are not limited to: grabbing students by the ear, arm and/or shirt and pushing them against walls, hitting students with a meter stick, refusing to allow students to use the bathroom, pinching students on their faces and shoulders, and pushing the eraser and point end of pencils in students’ faces. On or about May 20, 2002, the Miami-Dade County Schoo! District issued the CHRISTIAN PIERRE-ANTOINE Administrative Complaint 2 of 2 Respondent directives to refrain from using corporal punishment and to implement acceptable procedures for student discipline. He continues to be employed. STATUTE VIOLATIONS COUNT1: —TheRespondentis 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: TheRespondentis in 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 leaming 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 3 % day of Lk Tp ime J ORNE, as Commissioner of Education State of Florida

Docket for Case No: 04-003564PL