1 STATE OF FLORIDA" EDUCATIQN PRACTICES COMMISSION EEE] AN 10: 29 JOHN L. WINN, as Commissioner of Education, Petitioner, vs. Case Number: 034-0622-V BILLY MONROE BRADLEY, Respondent. Ol : O ‘Ole pL / ADMINISTRATIVE COMPLAINT Petitioner, John L. Winn, as Commissioner of Education, files this Administrative Complaint against BILLY MONROE BRADLEY. 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 323694, covering the area of Art which is valid through June 30, 2008. 2. At all times pertinent hereto, the Respondent was employed as an Art Teacher at DeLand High School in the Volusia County School District. MATERIAL ALLEGATIONS 3. During the 2001-2002 school year, the Respondent engaged in inappropriate and unprofessional conduct with a minor female student in that he attempted to establish a personal, romantic relationship with her. The Respondent stood unnecessarily close to the student, unnecessarily touched the student, gave her five rings and repeatedly made comments about what they could do together after she reached the age of eighteen. BILLY MONROE BRADLEY Administrative Complaint Page 2 of 3 OS FEB IT 4. During the 2002-2003 school year, the Respondent engaged in inappropriate and unprofessional conduct with another minor female student in that he attempted to establish a personal, romantic relationship with her as well. The Respondent stood unnecessarily close to the student, unnecessarily touched the student, commented on the student’s physical appearance, blew her a kiss at school, promised to give her a potter’s wheel, offered her money to clean his classroom and repeatedly made comments about what they could do together after she reached the age of eighteen. 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 in Florida prescribed by State Board of Education. 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 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. COUNT 5. The allegations of misconduct set forth herein are in violation of Rule 6B-1.006(3)(g), Florida Administrative Code, in that Respondent has harassed or discriminated against a student on the basis of race, color, religion, sex, age, national or ethnic origin, political beliefs, marital status, handicapping condition, or social and family background and has failed to make reasonable effort to assure that each student is protected from harassment or discrimination. 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, BILLY MONROE BRADLEY mniq oaMins Administrative Complaint 36 FE a AV . 2 . P G6 FEB IT BH10'29 Page 3 of 3 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. pe N EXECUTED on this 7 day of Ove mrbor 2005. Commissioner of Education, State of Florida

Docket for Case No: 06-000806PL