© py sur? STATE/OF ELORIDA EDUCATION ee tne COMMISSION 1003 OCT 28 A Il: 20 DR. ERIC J. SMITH, as INVISION OF Commissioner of Education, A 5 at ISTRATIVE HEARINGS Petitioner, ys. CASE NO. 078-2120-F GERALD CRAIG BRAGG, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Dr. Eric J. Smith, as Commissioner of Education, files this Administrative Complaint against GERALD CRAIG BRAGG. 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 726800, covering the areas of Health, Physical Education, and Driver Education, which is valid through June 30, 2011. 2. Atall times pertinent hereto, the Respondent was employed as a Physical Education Teacher at Milton High School in the Santa Rosa County School District. MATERIAL ALLEGATIONS 3. On or about September 15, 2003, students A.M., L.R., and C.R. reported to the West Florida High School guidance counselor that the Respondent made them uncomfortable by: A. Pressing one of the girls’ hands while talking to her; B. Massaging one of the girls’ shoulders while standing behind her; and Cc. Looking down one of the girls’ shirt. GERALD CRAIG BRAGG Administrative Complaint Page 2 of 4 4. On or about Septeniber 15, 2003, the school principal warned the Respondent about engaging in the behavior described in Paragraph 3 above. 5. During the 2004/2005 school year, the Respondent behaved inappropriately towards | student K.L., as follows: A. He singled out student KL. for inappropriate attention, repeatedly calling KL. out of other classes for little or no reason, ostensibly to help him with various projects; B. He gave K.L. money to purchase a camera, and asked her to take pictures of herself in her bathing suit; c. He behaved flirtatiously towards K.L.; and D. He told KL. “I can’t wait until you are 18 so I can take you to Vegas and show you a good time,” or words to that effect. 6. During the 2007/2008 school year, the Respondent engaged in inappropriate conduct towards 14-year-old female student, J.H., by hugging her and kissing her on the cheek in a manner that made the student uncomfortable. The Respondent also repeatedly asked J.H. why she did not want a boyfriend and told her she was beautiful. , 7. During the 2007/2008 school year, the Respondent hugged student C.R. and kissed her on the forehead. 8. During the 2007/2008 school year, the Respondent repeatedly pulled 13-year-old student, E.E., close to him, and hit her in the buttocks with a ball. 9. During the 2007/2008 school year, the Respondent engaged in inappropriate conduct, in that: A. He looked at female students in a leering or suggestive manner, B. He communicated with female students in a flirtatious manner, Cc. He singled out physically attractive female students to grade papers or do projects for him; and “D. He touched female students excessively and in a manner that made them uncomfortable. GERALD CRAIG BRAGG Administrative Complaint Page 3 of 4 The Petitioner charges: STATUTE, VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1)(b), Flotida Statutes, in that Respondent has proved to be incompetent to teach or to perform duties as an employee of the public school system or to teach in or to operate a private school. COUNT 2: 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 3: The Respondent is in violation of Section 1012.795( 1D, Florida Statutes, in that Respondent has been found guilty of personal conduct which. seriously reduces his effectiveness as an employee of the school board. COUNT 4: 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 COUNTS: 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 barmful to learning and/or to the student’s mental health and/or physical health and/or safety. COUNT 6: 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 disparagemient. (SIGNATURE ON FOLLOWING PAGE) GERALD CRAIG BRAGG 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 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 ZY day of Sune , 2008. Commissioner of Education State of Florida

Docket for Case No: 08-005408PL