STATE OF FLORIDA CUTS EDUCATION PRACTICES COMMISSION. SEP -7 PM 12h ¥-DdYDPL %% JOHN L. WINN, as OD Deo & Ca Commissioner of Education, Vb, N ty at RES, 9 > Oe “ea i” BOG OV Petitioner, BR, a Ss Ge vs. CASE NO, 023-0978 JUDY C. KARPIS, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, John L. Winn, as Commissioner of Education, files this Administrative Complaint against JUDY C. KARPIS. 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 533966, covering the area of Dental Assistant, which is valid through June 30, 2009. 2. At all times pertinent hereto, the Respondent was employed as a Teacher at Dr. Michael M. Krup Senior High School and Norland Middle School in the Miami-Dade County School District. MATERIAL ALLEGATIONS 3. During the 1999-2000 and 2001-2002 school years, Respondent received overall unsatisfactory evaluations at two different schools. Respondent also received numerous letters of reprimand for unprofessional behavior; battery on students and staff; inappropriate discipline; demeaning comments and intentional disparagement of students; threats and harassment of colleagues, administration, and parents; frequent absences; insubordination; and interfering with investigations and witnesses. Examples of Respondent’s behavior include, but are not limited to: : in JUDY C. KARPIS 65 SEP -7 PM 1:24 Administrative Complaint Page 2 of 4 a. grabbing a 12-year-old female student’s arm and digging her nails into the student’s skin; b. refusing to allow a female student to go to the bathroom after being informed that she had started menstruation, causing the student to soil herself and be humiliated in front of the class; c. scratching a teacher’s aide on the arm with a sharp metal object, causing the aide to bleed and require a tetanus shot; d. punching a male student in the chest, then threatening to write a referral for ‘the student if he wrote a statement about it; e. demanding that the ESE counselor tear up student statements about her behavior, and offering to tear up student referrals in exchange; f. referring a student to the office for allegedly threatening to shoot Respondent with a gun, when Respondent did not hear the student say anything of that nature; g. screaming at parents during conferences; and h. repeatedly blowing a police whistle at her students for over an hour. 4. As aresult of Respondent’s behavior, a large number of students were removed from her class, and administration received frequent oral and written complaints from parents, teachers, and other staff, requesting that Respondent be removed from the school. On or about June 10, 2002, the school board placed Respondent on alternate home assignment. On or about May 29, 2003, Respondent resigned. On or about June 19, 2003, the school board notified Respondent that she was precluded from future employment with the district. 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: 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. COUNT3: The Respondent is in violation of Section 1012.795(1)(i), Florida Statutes, in ose sstON : JUDY C. KARPIS OS SEP-7 PM 12h Administrative Complaint Page 3 of 4 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 5: 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 7: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(g), Florida Administrative Code, in that Respondent has harassed or discriminated 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 allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(4)(e), Florida Administrative Code, in that Respondent has offered gratuity, gift, or favor to obtain special advantages. COUNT 9: 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 10: 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 education or which created a hostile, intimidating, abusive, offensive, or oppressive environment; and further, failed to make reasonable effort to assure that each individual was protected from such harassment or discrimination. COUNT 11: The allegations of misconduct set forth herein are in violation of Rule 6B- OHS JUDY C. KARPIS OSSEP-7 PM I: 2k Administrative Complaint Page 4 of 4 1.006(5)(e), Florida Administrative Code, in that Respondent has made malicious or intentionally false statements about a colleague. COUNT 12: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(5)(), Florida Administrative Code, in that Respondent has used coercive means or promised special treatment to influence professional judgments of colleagues. COUNT 13: . The Respondent is in violation of Rule 6B.1006(5)(o), Florida Administrative Code, in that Respondent sought reprisal against any 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 the reasons set forth herein, and in accordance with the Explanation and Election of Rights forms which are attached hereto and made a part hereof by reference. EXECUTED on this 22. day of Sal 4 , 2005. JOHN L. WINN, as Commissioner of Education State of Florida

Docket for Case No: 08-002242PL