ICES 1OM STATE OF FLORIDA EDUCATION PRACTICES COMMISSION POMAR TL AN IO: 1g JOHN L. WINN, as Commissioner of Education, woe — re, > \e Petitioner, 0D ~ OF A A CL vs. CASE NO. 023-1755-C JOHN LOUIS GRAYSON, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, John L. Winn, as Commissioner of Education, files this Administrative Complaint against JOHN LOUIS GRAYSON. 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 305305, covering the areas of Guidance and Counseling and Social Science, which is valid through June 30, 2006. 2. At all times pertinent hereto, the Respondent was employed as a Guidance Counselor at Florida Agricultural and Mechanical University Developmental Research School in the Leon County School District. MATERIAL ALLEGATIONS 3, During 2002, following the administration of the 2002 Florida Comprehensive Assessment Test ("FCAT"), the Respondent participated in a testing security breach by maintaining a copy of the eighth and tenth grade math sections and the tenth grade reading section of the 2002 FCAT. He gave these materials to a teacher who then copied and distributed the materials to several teachers prior to the administration of the 2003 FCAT, advising them that the materials were practice tests. Students recognized some of the questions on the 2003 FCAT as questions they had seen on TICES S1ON JOHN LOUIS GRAYSON O5 MAR It AM IO: 18 Administrative Complaint Page 2 of 3 the 2002 FCAT, as the questions had been re-used. The Respondent also failed to maintain the 2003 FCAT materials in a secure location, resulting in the disappearance of one tenth-grade student's entire FCAT test package. He allowed teachers and test administrators to keep test packets in their classrooms until the end of the day, and did not require test administrators to sign for test materials for overnight storage. As a result of the testing improprieties, testing was suspended. His contract with the Leon County Schoo} District was not renewed. STATUTE VIOLATIONS COUNT 1: — The Respondent is in violation of Section 1012.795(1)(c), Flonda Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude. COUNT 2: The Respondent is in violation of Section 1012.795(1)(f), Flonda Statutes, in that Respondent has been found guilty of personal conduct which seriously reduces his effectiveness as an employee of the schoo} board. COUNT 3: The Respondent is 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 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 student’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(5)(a), Florida Administrative Code, in that Respondent has failed to maintain honestv in all professional dealings. JOHN LOUIS GRAYSON Administrative Complaint Page 3 of 3 OSMAR IL aMio: 1g 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 25 day of (OC@Toloer-__. 2004. Commissioner of Education State of Florida

Docket for Case No: 05-000993PL