ay STATE OF FLORIDA / P EDUCATION PRACTICES COMMISSION Of e40 a fry HS TM Oe JOHN L. WINN, as Comunissioner of Education, Petitioner, VS. CASE NO, 023-1218-B Ol-SOIaPL MARK WILSON, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, John L. Winn, as Commissioner of Education, files this Administrative Complaint against MARK WILSON. 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 234612, covering the areas of Emotionally Handicapped and Social Science, which is valid through June 30, 2009. 2. At all times pertinent hereto, the Respondent was employed as a Severcly Emotionally Disabled Teacher at Ben Sheppard Elementary School in the Miami-Dade County School District, MATERIAL ALLEGATIONS 3. During 2001 and 2002, Respondent harassed S.M., a fernale tcacher, by pinching her on the buttocks in the school cafeteria in the presence of other staff and students. 4, During 2001 and 2002, Respondent harassed C.L., a female assistant principal, by frequently berating her in the presence of staff, students, and parents; cursing and screaming at her; telling inappropriate jokes of a sexual nature in her presence; refusing to follow her directives: yelling and pointing his finger in her face in close proximity in a threatening manner, necessitating MARK WILSON Administrative Complaint Page 2 of 3 intervention by another staff member; threatening to “get her” for complaining about him: and telling colleagues C.L. had been thrown out of her previous school. Respondent further made it known to several staff members, including C.L., that he would not take dircctiun or orders from a woman. STATUTE VIOLATIONS COUNT 1: The Respondent is 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: Thc Respondent is in violation of Section 1012.795(1)(f), Florida Statutes, in that Respondent has been found guilty of personal conduct which seriously 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 State Board of Education rules. Ri VIOLATIONS COUNT 4: — The allegations of miscunduct set forth herein are in violation of Rule GB- 1.006(5)(a), Florida Administrative Code, in that Respondent has failed to maintain honesty in all professional dealings. COUNT 5; = The allegations of misconduct set forth herein are in violation of Rule 6B- 1,006(5)(d), Florida Administrative Code, in that Respondent has engaged in harassment or discriminatory conduct which unreasonably interfered with an individual’s performance of professional or work responsibilities or with the orderly processes of cduvation or which created a hostile, intimidating, abusive, offensive, or oppressive environment; and further, failed to make reasonable effort lo assure that each individual was protected from such harassment or discrimination. COUNT 6; = The allegations of misconduct sct forth herein are in violation of Rulc 6B- 1.006(5)(e), Florida Administrative Code, in that Respondent has made malicious or intentionally false statements about a colleague. (SIGNATURE ON FOLLOWING PAGE) MARK WILSON Administrative Complaint Page 3 of 3 WHEREFORE, based on the reasons set forth herein and in accordance with the Explanation of Rights and Election of Rights forms attached to and made a part of this Administrative Complaint, Petitioner respectfully recommends that the Education Practices Commission impose an appropriate sanction against the Respondent's educator’s certificate pursuant to the authority provided in Sections 1012.795(1) and 1012,796(7), Florida Statutes. The sanctions imposed by the Education Practices Commission may include, but are not limited to, any onc or a combination of the following: issuing the Rcspondent a written reprimand; placing the Respondent on probation for any period of time; restricting the Respondent’s authorized scope of practice; assessing the Respondent an administrative finc; directing the Respondent to enroll in the Recovery Network Program; suspending the Respondent's cducator’s certificate for a period of time not to exceed five years; revoking the Respondent's educator's certificate for a period of time up to 10 years or permanently; or barring the Respondent from reapplying for an educator's certificate for a period of time up to 10 ycars or permanently. EXECUTED on this 4034 day of , 2006. Commissioner of Education State of Florida

Docket for Case No: 06-005293PL