CES STATE OF FLORH EDUCATION PRACTICES COMMISSIONS JAN {2 AM 8:57 5 JAN 13 PM 119 JOHN L. WINN, as OW SIU OF Commissioner of Education, ADMINISTRAL? ‘vt HEARINGS Petitioner, VS. CASE NO. 023-0249-S ANGELA R. WILLIAMS, Os - C10 PU Respondent. ADMINISTRATIVE COMPLAINT Petitioner, John L. Winn, as Commissioner of Education, files this Administrative Complaint against ANGELA R. WILLIAMS. 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 L. The Respondent holds Florida Educator’s Certificate 698233, covering the areas of Athletic Coaching, English to Speakers of Other Languages (ESOL) and Foreign Language - -Spanish, which is valid through June 30, 2006. 2. At all times pertinent hereto, the Respondent was employed as an ESOL Teacher at Oak Ridge High School in the Orange County School District. MATERIAL ALLEGATIONS 4 3. During the 1997-1998 school year, the Respondent engaged in an inappropriate relationship with two female students, one of whom she kissed on the mouth in the presence of other students. On or about December 9, 1997, she received directives from her principal. During the 2001-2002 school year, the Respondent used her school computer to exchange sexually graphic e-mails with another teacher using his school computer. The e-mails miSSION ANGELA R. WILLIAMS 05 JAN 12 AM 8:57 Admunistrative Complaint Page 2 of 3 included statements to the effect of "You are beneath this New Orleans Playa [sic] because you want to fuck me and got played by the Queen Dominatrix, (you couldn't make me scream if we fucked in front of a firing squad)..." and "o.k. Iam almost there, just like the beginning ofa climax. I like to be the dominatrix (as you know). I love cybersex, it brings out the freak in the most reserved woman." During 2003, the Respondent used the school computer, as union representative, to write an e-mail encouraging subversion of school policies. She suggested to coworkers that if they decided not to serve their required hall duty, that the administration would have to prove that they were not serving, and stated "Who's to say that they [the administration] just didn't see you as you made your loop of the designated area?" She continues to be employed. STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1)(a), Florida Statutes, in that Respondent obtained the teaching certificate by fraudulent means. COUNT 2: — The Respondent is in violation of Section 1 012.795(1)(£), Florida Statutes, in that Respondent has been found guilty of persona] conduct which seriously reduces her effectiveness as an employee of the school board. COUNT 3: The Respondentis in violation of Section 1 012.795(1)(4), 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 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 learning and/or to the studen‘’s mental health and/or physical health and/or 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. COUNT 6: — The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3 }(h), Florida Administrative Code, in that Respondent has exploited a relationship with a student for personal gain or advantage. ANGELA R. WILLIAMS 05 JAN I2 AM 8:57 Administrative Complaint Page 3 of 3 COUNT 7: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(4)(c), Florida Administrative Code, in that Respondent has used institutional privileges for personal gain or advantage. COUNT 8: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(5)(£), Florida Administrative Code, in that Respondent has used coercive means or promised special treatment to influence professional judgments of colleagues. 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 R:ghts forms which are attached hereto and made a part hereof by reference. EXECUTED on this ge day of Navember , 2004. yon ‘ hr LY 174—~__ JOHN L. WINN, as Commissioner of Education State of Florida

Docket for Case No: 05-000103PL