STATE OF FLORIDA EDUCATION PRACTICES COMMISSION JEANINE BLOMBERG, as D-3eS { P L itp ed GHP Commissioner of Education, Hl 25 A I}: i Petitioner, ADM Nis Jif OE HEAR RATIVE vs. CASE NO. 056-3429-B JANE IRONS COUPE, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Jeanine Blomberg, as Commissioner of Education, files this Administrative Complaint against JANE IRONS COUPE. 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 691564, covering the areas of Elementary Education, English to Speakers of Other Languages (ESOL) and Physical Education, which is valid through June 30, 2007. 2. At all times pertinent hereto, the Respondent was employed as a Second Grade Teacher at McNeal Elementary School in the Manatee County School District. MATERIAL ALLEGATIONS 3. During the 2005/2006 school year, Respondent inappropriately disciplined students in her first grade class by using physical force and intimidation to control their behavior. On a regular basis, Respondent disciplined students by hitting them over the head with a book, painfully pinching them by grabbing their shoulder and back in a “claw” like manner, screaming at the class and telling them not to come back and taking students into a closet and applying physical force such that red marks were evidenced on their arms. On or about June 8, 2006, Respondent resigned in lieu JANE IRONS COUPE Administrative Complaint Page 2 of 3 of termination from her teaching position with the district. 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. COUNT 2: The Respondent is in violation of Section 1012.795(1)(0), 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 Respondentis in violation of Section 1012.795(1)(), 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 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. (SIGNATURE ON FOLLOWING PAGE) JANE IRONS COUPE 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 271 day of June . , 2007. ‘ ACANLRL JEANINE BLOMBERG, as Commissioner of Education State of Florida

Docket for Case No: 08-003651PL