STATE OF FLORIDA EDUCATION PRACTICES COMMISSION DR. ERIC J. SMITH, as Ot U0 KY PL Commissioner of Education, Petitioner, vs. CASE NO. 056-1883-R LEONARD LAGRANGE, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Dr. Eric J. Smith, as Commissioner of Education, files this Administrative Complaint against LEONARD LAGRANGE. 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 533140, covering the areas of Emotionally Handicapped and Physical Education, which was valid through June 30, 2008. 2. At all times pertinent hereto, the Respondent was employed as a Health Teacher at Port Charlotte High School in the Charlotte County School District. MATERIAL ALLEGATIONS 3. During the 2004/2005 school year, Respondent made inappropriate comments of a sexuai nature to students. Respondent’s actions include but are not limited to: A. When A.V., a fourteen-year-old, female student, was working at the board, Respondent told the rest of his class to look at her “cute little ass,” or words to that effect. B. Respondent told N.M., a fourteen-year-old, female student, “You are what LEONARD LAGRANGE Administrative Complaint Page 2 of 3 wet dreams are made of,” or words to that effect. ° Cc. While teaching a lesson on human reproduction, Respondent used A.V.’s name for the female genitals and his own name for the male. 4, On or about October 4, 2006, Respondent was terminated from his teaching position with the district. On or about April 18, 2006, the Division of Administrative Hearings issued a recommended order upholding Respondent’s termination. The Petitioner charges: STATUTE VIOLATIONS ° COUNT i: 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)(H, Florida Statutes, in that Respondent has been fourid guilty of personal conduct which seriously reduces his effectiveness as an employee of the school board. COUNT 3: 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 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. COUNT 6: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(g), Florida Administrative Code, in that Respondent 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. (SIGNATURE ON FOLLOWING PAGE) LEONARD LAGRANGE 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; restrig¢ting the Respondent’s authorized scope of practice; assessing the Respondent an administrative fine; directing the Respondent to enroll in the Recovery Network Prograin; suspending the Respondent’s educator’s certificate for a period of time not to exceed five years; revoking the Kespondent’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 _ yk ik day of “Suh 4 , 2008. J.SMITH, as nissioner of Education State of Florida

Docket for Case No: 09-004084PL