STATE OF FLORIDA EDUCATION PRACTICES COMMISSION 04. SadK PL DR. ERIC J. SMITH, as Commissioner of Education, Petitioner, vs. CASE NO. 078-0860-M BRENDA CROSKEY VEREEN, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Dr. Eric J. Smith, as Commissioner of Education, files this Administrative Complaint against BRENDA CROSKEY VEREEN. 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 313880, covering the area of Educational Media Specialist and Mentally Handicapped, which is valid through June 30, 2010. 2. At all times pertinent hereto, the Respondent was employed as an Exceptional Student Education Teacher at Wildwood Elementary School in the Sumter County School District. MATERIAL ALLEGATIONS 3. On or about August 21, 2007, Respondent engaged in inappropriate and unprofessional conduct when she called two male students “niggers.” On or about August 22, 2007, Respondent resigned from her position with the school board. The Petitioner charges: STATUTE VIGLATIONS COUNT i: The Respondent is in violation of Section 1012.795(1)(c), Florida Statutes, BRENDA CROSKEY VEREEN Administrative Complaint Page 2 of 3 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)(f, Florida Statutes, in that Respondent has been found guilty of personal conduct which seriously reduces her effectiveness as an employee of the schoo! board. COUNT3: 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: _ Theallegations 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) BRENDA CROSKEY VEREEN 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 14% aay of Vu ly , 2008. Commissioner of Education State of Florida

Docket for Case No: 09-005348PL