STATE GF FLORIDA EDUCATION PRACTICES COMMISSION JOHN L. WINN, as Commissioner of Education, Petitiouer, vs. CASE NO. 034-2544-D ANDREA A. COX, O1-1u! YPL Respondent. ADMINISTRATIVE COMPLAINT Petitioner, John L. Winn, as Commissioner of Education, files this Administrative Complaint against ANDREA A. COX. 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: JURISDICTI 1. The Respondent holds Florida Educator’s Certificate 440356, covering the area of English, which is valid through June 30, 2008. 2. At all times pertinent hereto, the Respondent was employed as a Teacher at Boca Ciega High School in the Pinellas County Schoo! District. MA! AL ALLEGA IN 3. Between 1994 and 2005, Respondent engaged in multiple acts of inappropriate, derogatory, discriminatory, and hostile conduct toward students, which included, but were not limited to: a. wriling a referral to the school nurse for a student which included the comment, “Here is our constipated prince-he needs an enema”; b. reading students' grades and wrong answers aloud in class; c, refusing to acknowledge black students who had their hands raised, and refusing to ANDREA A. COX Administrative Complaint Page 2 of 3 assist black students with their work; grading identical work differently, resulting in black students receiving lower grades; losing student work, (hen telling students they did not turn the work in; being unprepared for administering exams, or losing final exams; refusing to tet students go to the restroom or the clinic when they were ill; and when a student said she was so sick she felt like she could die, responding, “I should be so lucky!” rou mo oe 4. School adininistration received frequent complaints from students and parents regarding Respondent’s inappropriate conduct. As a result, Respondent was issued several directives, letters of reprimand, and suspensions without pay. STATUT. LATIONS 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: 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 arc in violation of Rule 6B- 1.006(3)(a), Flonida 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 menial health and/or physical health and/or safety. COUNT 5: The allegations of misconduct sct 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 sct forth herein are in violation of Rule 6B- 1,006(3)(), Florida Administrative Code, in that Respondent has intentionally violated or denied a student’s legal rights. COUNT 7: The allegations of misconduct set forth herein are in violation of Rule 6B- ANDREA A. COX Administrative Complaint Page 3 of 3 1.006(3)(g), Florida Administrative Code, in that Respondent has harassed or discriminaled against a student on the basis of race, color, religion, sex, age, national or ethnic origin, political beliefs, marital status, handicapping condition, sexual orientation, or social and family background and shall make reasonable effort to assure that each student is protected from harassment or discrimination. COUNT 8: The allogations of misconduct 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. WHEREFORE, based on the rcasons 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 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 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 execcd five years; revoking the Respondent’s educator’s certificate for a period of time up to 10 years or permanently; or barring tac Respondent from reapplying for an educator’s certificate for a period of time up to 10 years or permanently. EXECUTED on this (9% day of March _. 2006, i lle JOHN L. WINN, as Commissioner of Education State of Florida

Docket for Case No: 08-002206PL