STATE OF FLORIDA EDUCATION PRACTICES COMMISSION DR. ERIC J. SMITH, as Commissioner of Education, Petitioner, vs. CASE NO. 078-2924 STEPHANIE MARIE RAGUSA, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Dr. Eric J. Smith, as Commissioner of Education, files this Administrative Complaint against STEPHANIE MARIE RAGUSA. 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 1034851, covering the area of Middle Grades Integrated Curriculum, which was valid through June 30, 2009. 2. During the 2006 - 2007 school year, the Respondent was employed as Mathematics Teacher and Early Learning Program (ELP) Teacher at Davidsen Middle School in the Hillsborough County School District. During the 2007 - 2008 school year, the Respondent was employed as a Mathematics Teacher at Martinez Middle School in the Hillsborough County School District. MATERIAL ALLEGATIONS 3. Between October of 2006 through May of 2007, the Respondent engaged in inappropriate conduct with B.G., a male student, while B.G. was fourteen and fifteen years old. Specifically, the Respondent (a) met B.G. while B.G was a student and the Respondent was a teacher at Davidsen Middle School; and STEPHANIE MARIE RAGUSA Administrative Compiaint Page 2 of 4 (b) engaged in sexual activity with B.G. on several occasions. 4. Between February of 2007 through April of 2008, the Respondent engaged in inappropriate conduct with J.B., a male student, while J.B. was fifteen and sixteen years old. Specifically, the Respondent (a) met J.B. while JB. was a student and the Respondent was a teacher at Davidsen Middle School; (b) engaged in sexual activity with J.B. on several occasions; (c) provided aicohol to J.B.; (d) gave gifts to J.B.; (e) exchanged cards, notes and text messages with J.B.; and (£) engaged in sexual activity with J.B. in April of 2008 after the Respondent was released from custody following her arrest. 5. As a result of the conduct alleged in Paragraphs 3 and 4 of this Administrative Complaisit, the Respondent was arrested on three separate occasions in March and April of 2008 and charged with five counts of Lewd or Lascivious Battery, one count of Lewd or Lascivious Molestation, two counts of Contributing to the Delinquency or Dependency of a Minor, and two counts of Unlawful Sexual Activity with a Minor. 6. On or about June 5, 2008, the Hillsborough County School District terminated the Respondent from her position. 7. On or about April 12, 2010, the Respondent entered a plea of guilty to three counts of Lewd or Lascivious Battery with respect to student B.G. and two counts of Unlawful Sexual Activity with a Minor with respect to student J.B.. The court adjudicated the Respondent guilty of ali five charges. The remaining charges were nolle prossed. The Respondent was sentenced to serve ten years in prison followed by 15 years of sex offender probation. 8. Pursuant to Section 1012.795(2), Florida Statutes, the plea of guilty or the decision of guilty by a court is prima facie proof of grounds for the revocation or other sanction of a teaching certificate. 9. Pursuant to Section 1012.315(1)\(z) and (n), the Respondent is ineligible for teache ner certification because she has been convicted of offenses under Section 794.05 and Chapter 800, Florida Statutes. STEPHANIE MARIE RAGUSA Administrative Compiaint Page 3 of 4 The Petitioner charges: STATUTE VIOLATIONS COUNT 1: 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)(f), Florida Statutes, in that Respondent has been convicted or found guilty of, or entered a plea of guilty to, regardless of adjudication of guilt, a misdemeanor, felony, or any other criminal charge, other than a minor traffic violation. COUNT 3: 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 her effectiveness as an employee of the school board. COUNT 4: The Respondent is in violation of Section 1012.795(1)(j), Florida Statutes, in prescribed by State Boatd of Education rules. COUNT 5: The Respondent is subject to Section 1012.795(1)(n), Florida Statutes, in that Respondent has been disqualified from educator certification under 1012.315, Florida Statutes. RULE VIOLATIONS COUNT 6: 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 7: 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 8: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(h), Florida Administrative Code, in that Respondent has exploited a relationship with a student for personal gain or advantage. COUNT 9: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(4)(e), Florida Administrative Code, in that Respondent has offered gratuity, gift, or favor to obtain special advantages. STEPHANIE MARIE RAGUSA Administrative Complaint Page 4 of 4 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; 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 2.15" aay of July 2010. DR. ERIC J. SMITH, as Commissioner of Education State of Florida

Docket for Case No: 10-009239PL