STATE OF FLORIDA EH ED EDUCATION PRACTICES COMMISSION = Bese ew | 07-259 3rE- JOHN L. WINN, as Commissioner of Education, Petitioner, ys. CASE NO. 056-3095-F MARGARET DAWN BILLINGS, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, John L. Winn, as Commissioner of Education, files this Administrative Complaint against MARGARET DAWN BILLINGS. 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 840947, covering the areas of Readings, Social Science and Exceptional Student Education, which is valid through June 30, 2007. 2. At all times pertinent hercto, the Respondent was employed as an SLD Teacher at Baker County Middle School in the Baker County School District. MATERIAL ALLEGATIONS 3. During March, 2006, Respondent used her position as an educator to gain access to non-public, student, disciplinary records of R.S., a fourteen-year-old, male, ESE student who had been bullying Respondent’s son. Respondent submitted R.S.’s student records to a court of law to become part of a public record in a proceeding to obtain a Temporary Injunction for Protection Against Repeat Violence. On or about March 8, 2006, Respondent entered into a Settlement Agreement with the district whcreby, she would resign from her teaching position effective March 29, 2006. MARGARET DAWN BILLINGS Administrative Complaint Page 2 of 3 The Petitioner charges: stAire Siok dinbiks Sivision oF ; ; COUNT 1: The Respondent ji:iu-igletion of,Section 1012.795(1}(c), Florida Statutes, in that Respondent has been guilty of grossimmorality of an act involving moral turpitude. COUNT 2: The 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 her effectiveness as an employee of the school 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 §: 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)(f), Florida Administrative Code, in that Respondent has intentionally violated or denied a student’s legal rights. COUNT ?: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(h), Florida Administrative Code, in that Respondent has exploited a relationship with a student for personal gain or advantage. COUNT 8: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3\i), 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 9: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(4)(c), Florida Administrative Code, in that Respondent has used institutional privileges for personal gain or advantage. ARGARET DAWN BILLINGS c 2 Administrative Complaint Page 3 of 3 WHEREFORE, based on the reasons 4} foith hereifahlf ih Uccordance with the Explanation of Rights and Election of Rights. forms. attached to and made a part of this Administrative Complaint, Petitioner respectfully i that the Education Practices Commission impose an appropriate sanction a lent’s educator’s cerlificate pursuant to the authority provided in Sections 1012.795(1) and {012. 796(7), Florida Statutes. The sanctions imposed by the Education Practices Commission may include, but are not limited to, any one or a combination of the following: issuing the Respondent a wriiten reprimand; placing the Respondent on probation for any period of time; restricting the Respondent’s authorized scope of practice; assessing the Respondent an administrative fine; directing the Respondent to enroll in the Recovery Network Program; suspending the Respondent’s educator’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 years or permanently. EXECUTED on this \a day & Decem b eg", 2006. faite Commissioner of Education State of Florida

Docket for Case No: 07-003593PL