STATE OF FLORIDA EDUCATION PRACTICES COMMISSION OF 3M PL JEANINE BLOMBERG, as v 5 {t f Commissioner of Education, Petitioner, vs. CASE NO. 056-2425-A LINDA PEOPLES, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Jeanine Blomberg, as Commissioner of Education, files this Administrative Complaint against LINDA PEOPLES. 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 825769, covering the area of Exceptional Student Education, which was valid through June 30, 2007. 2. At all times pertinent hereto, the Respondent was employed as an Exceptional Student Education Teacher in the Homebound Program in the Palm Beach County School District. MATERIAL ALLEGATIONS 3. On or about April 9, 2000, Respondent provided false information regarding another teacher under investigation for an improper relationship with a minor, female student. Over the course of the investigation and prosecution of the other teacher, even though Respondent had first hand knowledge of the situation, she repeatedly failed to provide information to district and state investigators. : LINDA PEOPLES Administrative Complaint Page 2 of 3 The Petitioner charges: 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. COUNT2: 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 3: 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 merital health and/or physical health and/or safety. COUNT 4: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(4)(b), Florida Administrative Code, in that Respondent has intentionally distorted or misrepresented facts concerning an educational matter in direct or indirect public expression. COUNT 5: 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 6: The Respondentis in violation of Rule 6B. 1006(5)(1), Florida Administrative Code, in that Respondent has assisted into entry or continuance in the profession ofa person known to be unqualified in accordance with the Principles of Professional Conduct of the Education Profession in Florida and other applicable Florida Statutes and State Board of Education Rules. COUNT7: TheRespondentis in violation of Rule 6B.1006(5)(n), Florida Administrative Code, in that Respondent failed to report to appropriate authorities any known allegation of a violation of the Florida School Code or State Board of Education Rules as defined in Section 1012.795(1), Florida Statutes. (SIGNATURE ON FOLLOWING PAGE) LINDA PEOPLES 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 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 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 5S day of , 2007. ANINE BLOMBERG, as Commissioner of Education State of Florida

Docket for Case No: 08-003466PL