STATE OF FLORIDA EDUCATION PRACTICES COMMISSION JEANINE BLOMBERG, as 0) 1- () SO ( C Commissioner of Education, Petitioner, vs. CASE NO. 056-3596-P ANTHONY GRAHAM, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Jeanine Blomberg, as Commissioner of Education, files this Administrative Complaint against ANTHONY GRAHAM. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educator’s certificate putsuant 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 849341, covering the areas of Educational Leadership and Elementary Education, which is valid through June 30, 2009. 2. At all times pertinent hereto, the Respondent was employed as a Teacher at Carol City Elementary School in the Miami-Dade County School District. MATERIAL ALLEGATIONS 3. On or about December 24, 2005, Respondent lured a sixteen-year-old male into his home with the promise of money. Once inside, Respondent instructed the minor to go into the bedroom and pull down his pants. Respondent was arrested and charged with one count of Interfering With the Custody of a Minor. The state attorney’s office deferred prosecution of this case pending Respondent’s completion of a pre-trial intervention program. ANTHONY GRAHAM 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. COUNT 2: 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 harinful to learning and/or to the student’s mental 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(3)(e), Florida Administrative Code, in that Resporident has intentionally exposed a student to unnecessary embarrassment or disparagement. COUNTS: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(g), Florida Administrative Code, in that Resporident 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 6: The allegations of misconduct set forth herein are in violation of Rute 6B- 1.006(3)(h), Florida Administrative Code, in that Respondent has exploited a relationship with a student for personal gain or advantage. (SIGNATURE ON FOLLOWING PAGE) ANTHONY GRAHAM 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. f 2 EXECUTED on this 22" day of Merch , 2007. 4 VY} AAR ERLE JE BLOMBERG, as Commissioner of Education State of Florida

Docket for Case No: 09-000501PL