STATE OF FLORIDA EK EDUCATION PRACTICES COMMISSION tg Commissioner of Education, DR. ERIC J. SMITH, as \O-3il9 PL & Petitioner, vs. CASE NO. 078-2102-H JEROME JAMES ODELL, Respondent. ~ ADMINISTRATIVE COMPLAINT Petitioner, Dr. Eric J. Smith, as Commissioner of Education, files this Administrative Complaint against JEROME JAMES ODELL. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educator’s certificate pursuant to Sections 1012.315, 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 807162, covering the area of Mathematics, which is valid through June 30, 2011. 2. Atall times pertinent hereto, the Respondent was employed as a Mathematics Teacher at Boca Ciega High Schooi in the Pinellas County School District. MATERIAL ALLEGATIONS 3. Respondent has been employed by the Pinellas County School District (District) as a classroom teacher since 1999. He was granted a professional service contract on July 30, 2003. 4. Respondent has taught mathematics at Boca Ciega High School (BCHS) in southern. Pinellas County since 1999. He is a certified mathematics teacher. JEROME JAMES ODELL Administrative Complaint Page 2 of 7 5. BCHS adminisiraiors decided towards the end of the 2005-06 school year to add a pre-engineering program to the school’s curriculum for the 2006-07 school year. 6. BCHS administrators approached. Respondent in the spring of 2006 and asked whether he would be interested in teaching an introductory engincering course during the following school year since he had worked as an engineer prior to becoming a teacher. Respondent agreed to do so. 7. The pre-engineering curriculum offered at BCHS was developed by a nationally- recognized organization known as Project Lead the Way (PLTW). The PLTW curriculum is designed to expose students to engineering concepts and skills in order to prepare them for higher education and careers in engineering. 8. PLTW offers a number of courses, and schools are required to offer a minimum of four of the courses, including three foundation courses. Some of the PLTW courses allow students to earn college credit, similar to an Advanced Placement course. 9. The PLTW curriculum was first introduced in the District in 2002 at East Lake High School (ELHS) in northern Pinellas County. The PLTW curriculum at ELHS is the centerpiece of the school’s successful “engineering academy.” 10. BCHS planned to offer a PLTW foundation course known as Principles of Engineering (POE) in the 2006-07 school year. This. was an appropriate:course for the start-up program at BCHS. No other PLTW courses were offered at BCHS, and students did not carn college credit for the POE course. Il. The District’s contract with PLTW requires the District to lease or purchase the materials necessary for teachers to teach the PLTW curriculum. The necessary materials include computers for the students as well as specialized engineering software, such as Auto Cad/Inventor Pro and Robo Pro. 12. _ It is not possible for a teacher to competently teach the POE course in accordance with the PLTW standards without the necessary materials, including the specialized engineering software. 13. The District’s contract with PLTW requires the teacher to administer the standardized written exam provided by PLTW at the end of each coursé. The exam is an important element of the PLTW curriculum, particularly for those courses that offer college credit. 14. PLT W expects school-based administrators to have a general understanding of the program and to provide support for the teacher in order to ensure successful implementation of the JEROME JAMES ODELL Administrative Complaint Page 3 of 7 program. 15. BCHS expected Respondent to get the course up and running, and they relied upon him to do so. : 16. The District sent Respondent to a two-week training program administered by PLTW during the summer before the 2006-07 school year. The purpose of the training program was to teach teachers exactly what they need to know to teach a POE course in accordance with the standards developed by PLTW. 17. The materials provided to the teachers at the training program included detailed “unit plans” outlining the concepts, lessons, and activities that teachers were to cover each day during the course. The unit plans identified the projects to be assigned and completed by students, as well as the assessment tools to be used by the teacher in evaluating the students’ work. 18. Respondent received the POE curriculum and the unit plans, both in written and electronic format at the training program that he attended. Specialized engineering software was also downloaded onto his District-issued laptop computer. 19. PLTW expects teachers te follow strictly the unit plans provided at the training program when teaching the POE course. This expectation, as well as the expectation that all students are to take the standardized, written PLTW final exam, was communicated to Respondent at the training program he attended. 20. BCHS was on a “four-by-four” schedule during the 2006-07 school year, which means that students attended four 80-minute classes each day rather than six 50-minute classes. A course that takes two semesters to teach on a traditional schedule is taught in a single semester on a four-by-four schedule. 21. The POE course is designed to be a year-long course, but because of the four-by-four schedule at BCHS, Respondent taught two separate POE courses during the 2006-07 school year. The first course started in August 2006 and ended in January 2007 (hereafter “the first POE course”), and the second course started in January 2007 and ended in May 2007 (hereafter “th second POE course”). : 22. Respondent was not provided laptop computers for the students or the necessary specialized engineering software for the computers prior to the start of the first POE course. He also did not have a printer in his classroom. 23. On August 23, 2006, approximately two weeks into the school year, Respondent sent an e-mail to Jerry Ditty, the District’s contact person for the PLTW program, listing the materials JEROME JAMES ODELL Administrative Complaint Page 4 of 7 that he needed in order to teach the POE course, The list included laptop computers for the students as well as “software to load onto the laptops.” The e-mail did not clearly identify the type of specialized engineering software that Respondent needed. 24. Respondent continued over a period of months to request the computers and other materials through e-mail communications with Mr. Ditty. These requests focused on the computers and printer, not the specialized engineering software needed to teach the PLTW program. 25. Respondent never told the administration that he needed any specialized engineering software, and the assistant principal offered several alternatives (e.g., use of a nearby computer lab) to Respondent until the students’ laptop computers and the printer arrived. 26. Respondent received the students’ laptop computers in December 2006, towards the end of the first POE course. He never received the necessary specialized engineering software for the computers or a printer for his classroom. 27. Respondent did not teach the PLTW curriculum or administer the standardized PLTW final exam during either of the POE courses. The Respondent substituted an improvised cutriculum he created that was mostly unrelated to engineering, was insubstantial, and was inadequate to meet the educational needs of the students in the class. 28. Every student in the POE courses taught by Respondent received an “A” as a final grade. These grades were false and/or misleading in that the grades were assigned with disregard for the intended curriculum, the grades were based on insubstantial academic performance, and the substituted curriculum bore no reasonable relation in substance, difficulty or scope to the designated course. 29. | BCHS administrators did not learn that Respondent had not been teaching the course in accordance with the PLTW curriculum until after the second POE course was completed. 30. BCHS and District administrators began investigating Respondent’s teaching of the POE course after he and the students did not show up for the class on final exam day, May 17, 2007. 31. Respondent explained that he did not show up for the class on that day because all of the students had taken a “project-based exam” in lieu of a written final exam or were “exempted” from taking a final exam. 32. School Board Policy 5.15(4)(a) explains that a final exam is to be “a comprehensive assessment covering the course student performance standards for the entire term.” JEROME JAMES ODELL Administrative Complaint Page 5 of 7 33. Itis expected that the final exam will be a written, “sit down paper and pencil exam.” However, School Board policy does not expressly prohibit “project-based exams,” and such exams may be appropriate in certain types of courses, such as music. 34. The final exam, whether written or project-based, must be comprehensive and cover all of the subjects that are supposed to be taught in the course, which, as in this case, may not be the same as what was actually taught. 35. School Board Policy 5.15(4)(c) provides that a student can be “exempted” from taking the final exam if his or her provisional grade in the class is at least a“B” and ifhe or she has no more than five absences. 36. This policy does not exempt students in Advanced Placement or International Baccalaureate courses from taking the exams required for college credit, nor does it exempt students in the POE course from taking the standardized written final exam required by PLTW. 37. _ Respondent gave the District and BCHS administrators a variety of excuses during the course of the investigation as to why he did not administer the PLTW final exam. Among other things, he falsely claimed that he was authorized by the assistant principal at BCHS to administer a project-based exam and that he did not have access to the PLTW website to download the standardized written exam. 38. Respondent did not administer the PLTW exam because the students could not have passed the exam. The students’ inability to pass the final exam was a direct result of Respondent’s failure to teach the PLTW curriculum. 39. Respondent told the District and BCHS administrators during the course of the investigation that he administered a project-based exam during the last week of school and that the exam included definitions and research projects. 40. Respondent presented the District investigator a number of forms signed by students in the second POE course in an effort to corroborate his claim that he administered project-based exams to the students during the last week of the course. 41. The forms, which were drafted by Respondent and signed by the students in November 2007, stated that the students completed four assignments consisting of a research or invention project, writing a computer program using an Excel spreadsheet, a set of engineering questions, and definitions from a drafting book, during the last week of class. The form also stated that the assignments “constitute the final exam grade” and that "It was clearly stated to me that these assignments were to be counted as a project grade. It was clearly stated to me, those required to take the final exam, that these assignments were to be counted as my final exam. I agree that I saved my JEROME JAMES ODELL Administrative Complaint Page 6 of 7 work to one of the five flash-drives in class." 42. Student interviews and testimony have revealed that the statements on the form are false in several respects. Most significantly, the assignments referenced on the forms were not completed during the last week of school, but rather were completed over the course of the semester. 43. Additionally, contrary to the implication created by Respondent through the wording of the forms, the research and Excel projects that the students performed had nothing to do with engineering. Instead, the projects involved “pretend businesses” and the students’ favorite musicians. 44, The Respondent’s conduct reduced his effectiveness as an employee of the district because his dishonesty throughout the academic year and during the investigation demonstrate that he is untrustworthy, and because the students in his POE class were deprived of an exceptional program by the Respondent’s failure to adhere to the PLT W curriculum. The Petitioner charges: STATUTE VIOLATIONS COUNT i: The Respondent is in violation of Section 1012.795(1)(d), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude as defined by rule of the State Board of Education. COUNT 2: The Respondent is in violation of Section 1012.795(1)(g), 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: The Respondent is in violation of Section 1012.795(1)(), 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)(d), Florida Administrative Code, in that Respondent has intentionally suppressed or distorted subject matter relevant to a student’s academic program. COUNT 5: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(5)(a), Florida Administrative Code, in that Respondent has failed to maintain honesty in all professional dealings. . JEROME JAMES ODELL Administrative Complaint Page 7 of 7 COUNT6: The Respondentis in violation of Rule 6B.1006(5)(h), Florida Administrative Code, in that Respondent has submitted fraudulent information on a document in connection with professional activities. 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 writien 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; determining the Respondent to be ineligible for certification; 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 qth day of Occhober 2008, Commissioner of Education State of Florida

Docket for Case No: 10-003115PL