STATE OF FLORIDA oa : ad EDUCATION PRACTICES COMIMISS ON. AH 8:54 JOHN L. WINN, as Commissioner of Education, 05-216 PL Petitioner, Ly vs. Case Number: 023-18904 EDWARD ROGER STARCHER, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, John L. Winn, as Commissioner of Education, files this Administrative Complaint against EDWARD ROGER STARCHER. 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-1006, 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 590488, covering the areas of Physical Education and Driver Education which is valid through June 30, 2008. 2. At all times pertinent hereto, the Respondent was employed as a Drivers Education Teacher at Naples High School in the Collier County School District. MATERIAL ALLEGATIONS 4 3. On or about December 16, 1997, the Respondent attempted to hit his former wife with his automobile while returning their children from a visitation. Respondent’s former wife was sandwiched between her vehicle and the Respondent's oncoming vehicle, which she avoided by jumping onto or against her vehicle. 4. During the 2002-2003 school year, the Respondent engaged in EDWARD ROGER STARCHER Administrative Complaint Page 2 of 3 inappropriate conduct of a sexual nature in that he (a) made improper and unprofessional remarks about a female teacher's appearance and suggested that they engage in sexual conduct together; (b) made inappropriate and unprofessional remarks to one or more minor female students about their appearance, suggested they engage in a personal relationship and made references to sexual conduct; (c) touched one or more female students on the buttocks; and (d) entered a storage closet behind a female student, kissed her neck and lips, pressed his penis against the student’s body, grabbed his penis and stated “this is what you do to me.” or words of similar import. The Respondent also told the student that he could not guarantee that a similar incident would not happen again, and he made the student swear she would not tell anyone. STATUTE VIOLATIONS COUNT 1. The allegations of misconduct set forth herein are 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. COUNT 2. _ The allegations of misconduct set forth herein are 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 failed to make reasonable effort to protect the student from conditions harmful to learning and/or to the student’s mental 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 intentionally exposed a student to unnecessary embarrassment or disparagement. EDWARD ROGER STARCHER 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 1012.795(1) and 1012.796(7), Florida Statutes, which penalty may include a reprimand, probation, restriction of the authorized scope of practice, administrative tine, 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. L, > “4 EXECUTED on this 225 “aay of C694. _ 2005, Kf L. Winn, as Commissioner of Education, State of Florida

Docket for Case No: 05-002766PL