STATE OF FLORIDA EDUCATION PRACTICES COMMISSION JEANINE BLOMBERG, as Ot SUT pL Commissioner of Education, Petitioner, vs. CASE NO. 056-3745-F LATONYA LATREECE COOPER, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Jeanine Blomberg, as Commissioner of Education, files this Administrative Complaint against LATONYA LATREECE COOPER. 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 spevifically 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 838005, covering the areas of Elementary Education and English to Speakers of Other Languages (ESOL), which is valid through June 30, 2011. 2. At all times pertinent hereto, the Respondent was employed as a Curriculum Specialist at Lauderdale Manors Elementary School in the Broward County School District. MATERIAL ALLEGATIONS 3. During the Spring 2006 administration of the Florida Comprehensive Assessment Test (FCAT), Respondent failed to administer the test in a manner that would preserve the integrity of the test and to insure that all students worked independently. Respondent's assistance included but was not limited to reading materials 10 students and providing clues to answers. On or about May 25, 2006, the Florida Department of Education, Assessment and School Performance, Accountability, Rescarch and Measurement, invalidated the scores of 13 students whose lests had LATONYA LATREECE COOPER Administrative Complaint Page 2 of 4 been administered by Respondent. 4, On or about June 29, 2006, Respondent was notified that a case had becn opened against her by the Burean of Professional Practices Services in the Florida Department of Education as the result of allegations of standardized testing violations. Respondent was informed that the allegations could lead to discipline up to and including permanent revocation of her Florida Educator’s Certificate. On or about June 13, 2007, Respondent submitted a district employment application on which she answered ‘no’ to question 16; ‘Is disciplinary action currently pending anywhere against your teaching certificate?’ The Petitioner charges: STATUTE VIOLATI COUNT1: The Respondent is in violation of Section 1008,24(1), Florida Statutes, in that Respondent knowingly and willfully violated test security rules adopted by the State Board of Education for mandatory tests administcred by or through the State Board of Education or the Commissioner of Education to students, educators, or applicants for certification or administered by school districts pursuant to s. 1008.22. COUNT 2: The Respondent is in violation of Section 1008.24(1)(c), Florida Statutes, in that Respondent coached during testing; interfored with examine responses. COUNT 3: The Respondent is in violation of Section 1008.24(1)(f), Florida Statutes, in that Respondent knowingly and willfully failed to follow test administration directions specified in the test administration manuals. COUNT 4: ‘The Respondent is in violation of Section 1008.24(1 }(g), Florida Statutes, in that Respondent participated in, directed, aided, counseled, assisted in, or encouraged any of the acts prohibited in this section. COUNT 5: — 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 6: 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 7: The allegation of misconduct set forth are herein are in violation of Rule 6A- 10.042(1), Florida Administrative Code, in that Respondent failed to maintain/administer test in a LATONYA LATREECE COOPER Administrative Complaint Page 3 of 4 manner to preserve test integrity. COUNTS; The allegation of misconduct set forth are herein arc in violation of Rule 6A- 10.042(1)(c), Florida Administrative Code, in that Respondent assisted cxaminees in answering questions, COUNTS: The allegation of misconduct set forth are herein are in violation of Rule 6A- 10.042(1}(d), Florida Administrative Code, in that Respondent interfered with cxaminees' answers while administering test. COUNT 10: The allegation of misconduct set forth are herein are in violation of Rule 6A- 10.042(1)(), Florida Administrative Codec, in that Respondent has participated in, directed, aided counseled, assisted in, or encouraged an activity which could result in the inaccurate measurement or reporting of examinees’ achievement. COUNT 11: The allegations of misconduct sct forth herein are in violation of Rule 6R- 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 12: The allegations of misconduct set forth herein arc in violation of Rule 6B- 1.006(3)¢b), Florida Administrative Code, in that Respondent has unreasonably restrained a student from independent action in pursuit of learning. COUNT 13: The allegations of misconduct set forth hercin are in violation of Rule 6B- J,006(3)(d), Florida Administrative Code, in that Respondent has intentionally suppressed or distorted subject matter relevant to a student’s academic program. COUNT 14: 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 cmbarrassment or disparagement. COUNT 15: 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. COUNT 16: The Respondent is in violation of Rule 6B..1006(5)(i), Florida Administrative Code, in that Respondent made a fraudulent statement or failcd to disclose a material fact in one’s own or another’s application for a professional position. (SIGNATURE ON FOLLOWING PAGE) LATONYA LATREECE COOPER Administrative Complaint Page 4 of 4 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 one or a combination of the following: issuing the Respondent a writtcn 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 permanenily. EXECUTED on this. \Le day of Val “ , 2007. ANINE BLOMBERG, as Commissioner of Education State of Florida

Docket for Case No: 07-005671PL