STATE OF EEQRIDS EDUCATION FRACTIONS COMMISSION? ~2 pH 3 , 52 7009 HAR -S A 10 40 DR. ERIC J. SMITH, as SIVISION OF sacs . CiVISIO’ Commissioner of Education, ADAINISTR ATIVE . HEARINGS Petitioner, (9 : vs. 4 WT PL CASE NO. 067-3194-F KARL STEPHAN SIMMONS, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Dr. Eric J. Smith, as Commissioner of Education, files this Administrative . Complaint against KARL STEPHAN SIMMONS. 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 308836, covering the areas of Mathematics, General Science, Physics, and Business Education, which is valid through June 30, 2011. 2. At all times pertinent hereto, the Respondent was employed as a Mathematics Teacher at First Coast High School in the Duval County School District. MATERIAL ALLEGATIONS 3. During the 2006-2007 school year, Respondent used his school issued computer to access and to attempt to access pornographic internet sites in his classroom during his duty day. Effective January 31, 2007, Respondent resigned his position with the school board. KARL STEPHAN SIMMONS 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)(8), Florida Statutes, in that Respondent has been found guilty of personal conduct which seriously reduces his effectiveness as an employee of the school board. , COUNT3: TheRespondentis 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 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(4)(c), Florida Administrative Code, in that Respondent has used institutional privileges for personal gain or advantage. (SIGNATURE ON FOLLOWING PAGE) KARL STEPHAN SIMMONS 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_ 2U% day of “Yuan. , 2008. Commissioner of Education State of Florida

Docket for Case No: 09-001167PL