STATE OF FLORIDA CY a) EDUCATION PRACTICES COMMISSION én, > y ctl | Liefbip, Vy GELS EY "Y DR. ERIC J. SMITH, as | ()- (p22 PL Ap hg OF go Commissioner of Education, "eS Ye Petitioner, VS. CASE NO. 090-1392 JONATHAN H. DICKISON, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Dr. Eric J. Smith, as Commissioner of Education, files this Administrative Complaint against JONATHAN H. DICKISON. The Petitioner secks 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 822614, covering the areas of Physical Education and Social Science, which is valid through June 30, 2014. 2. At all times pertinent hereto, the Respondent was employed as a Physical Education Teacher at Seminole High School in the Seminole County School District. MATERIAL ALLEGATIONS 3. During September and October of 2009, the Respondent engaged in inappropriate conduct toward E.M., a sixteen year old female student. Specifically: (a) the Respondent exchanged numerous text messages with E.M. ofa personal and intimate nature, including telling E.M. that he loved her and desired her, and expressing an emotional attachment to E.M.; (b) the Respondent hugged and kissed E.M. on several occasions, JONATHAN H. DICKISON Administrative Complaint Page 2 of 3 (c) the Respondent gave E.M. money and a sweatshirt. On one occasion, while paying E.M. to purchase an air compressor for $50.00 from E.M.’s parents, the Respondent gave E.M. a separate envelope with $50.00 and told her to keep it in a safe place for herself. On another occasion, when E.M. told the Respondent that she did not want to continue the relationship, the Respondent gave E.M. an envelope containing $100.00. (d) the Respondent frequently met with E.M. before, during and after school to discuss matters of a personal nature with E.M.; and (e) the Respondent attempted to keep his relationship with E.M. a secret, in that he met with her when others were not present and told E.M. that they had to “ease up on stuff until it cools down.” 4, On or about October 13, 2009, the Seminole County School District suspended the Respondent from his position and subsequently notified the Respondent that it intended to terminate the Respondent’s employment for misconduct. On or about December 10, 2009 the Respondent submitted a letter of resignation. 5. The Respondent has been previously sanctioned by the Education Practices Commission in that on or about March 4, 2005, the Commission issued a Final Order issuing the Respondent a letter of reprimand for striking a student. 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)(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)Q), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession prescribed by State Board of Education rules. JONATHAN H. DICKISON Administrative Complaint Page 3 of 3 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)(h), Florida Administrative Code, in that Respondent has exploited a relationship with a student for personal gain or advantage. 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. L EXECUTED on this_ V2 day of 7 July , 2010. SZ, DR. E J. SMITH, as Commissioner of Education State of Florida

Docket for Case No: 10-010023PL