fe tf Ep , STATE OF FLORIDA Mp Oe ° EDUCATION PRACTICES COMMISSION CL is 4 oj yw be. oN, S/OKy a7 . JOHN L. WINN, as 48 TR ge Commissioner of Education, IN Get / Ve Petitioner, vs. CASE NO, 023-0516-M JOHN R. LACASSE ; , Dies Pe Respondent. . / ADMINISTRATIVE COMPLAINT’ Petitioner, John L. Winn, as Commissioner of Education, files this Administrative Complaint against JOIIN R. LACASSE. The Petitioncr sccks 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 sanctians specifically set forth in Sections 1012.795(L) and 1012.796(7), Florida Statutes. ‘Lhe Petitioner alleges: JURISDICTION 1. The Respondent holds Florida Educator’s Certificate 563621, covering the areas of English to Speakers of Other Languages and School Principal, which is valid through June 30, 2005. 2. At all times pertinent hereto, the Respondent was employed as a Principal at Nova High School in the Broward County School District. MATERIAL ALLEGATIONS 3. On or about May 18, 2002, Respondent was under the influence of alcohol at the school prom. That evening, and in the following weeks during school hours, several faculty memhers and students openly expressed disapproval of Respondent because of his behavior al the prom. 4. On or about January 10, 2005, through counsel, Respondent made false and/or malicious statements about several assistant principals, leuchors, other staff members, and students of the school in documentation provided to a Professional Practices Services investigator. JOHN R, LACASSE Administrative Complaint Page 2 of 3 Respondent further provided the investigator with copies of correspondence and information relating to the confidential medical conditions ofan assistant principal and a staff member. Respondent also represented to the investigator that district investigations were opened on his colleagues for cthical violations, when in fact no such action had been taken. STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Scction 1012.795(1)(c), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude. COUNT2: The Respondentis in violation of Section 1012.795(1)(£), Florida Statutes, in that Respondent has been found guilty of personal conduct which scriously reduces his effectiveness as an employee of the school board. COUNT3 : The Respondent isin 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 Slate Board of Education rules. RULE VIOLATIONS COUNT 4: The allegations of misconduct set forth herein are in violation of Rule GB- 1.006(3)(a), Florida Administrative Code, in that Respondent has failed to make reasonable cffort to protect the student from condilions harmful to learning and/or to the student’s mental health and/or physical health and/or safety, COUNTS: 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)G), Florida Administrative Code, in that Respondent has failed to keep in confidence personally identifiable information obtained in the course of professional services, unless disclosure serves professional purposes or is required by law. COUNT 7: 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 honesty in all professional dealings. JOHN R. LACASSE Administrative Complaint Page 3 of 3 COUNT 8: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(5)(e), Florida Administrative Code, in that Respondent has made malicious or intentionally falsc statements about a colleague. COUNT9: The Respondentis in violation of Rule 6B.1006(5)(h), Florida Administrative Code, in that Respondent has submitted fraudulent information on a document in connection with professional activities. COUNT 10: TheRespondentisin violation of Rulc6B.1006(5)(0), Florida Administrative Code, in that Respondent sought reprisal against eny individual who has reported an allegation of a violation of the Florida School Code or State Board of Education Rules as defined in Section 1012.795(1), Florida Statutes. 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 thc reasons set forth herein, and in accordance with the Explanation and Election of Rights forms which arc attached hereto and made a part hereof by reference. EXECUTED on this_ “22 day of Suly , 2005, JOHN L. WINN, as : Commissioner of Education Stale of Florida

Docket for Case No: 06-004851PL