STATE OF FLORIDA EDUCATION PRACTICES COMMISSION Commisionerorzaventon, — |()—|O5ISPL Petitioner, vs. | CASE NO. 089-0591 JONATHAN MATTHEW LOWNDES, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Dr. Eric J. Smith, as Commissioner of Education, files this Administrative Complaint against JONATHAN MATTHEW LOWNDES. 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: SCRISDICTION 1. The Respondent holds Florida Educator’s Certificate 892226, covering the area of English, which is valid through June 30, 2010. 2. At all times pertinent hereto, the Respondent was employed as an English Teacher at Charles W. Flanagan High School in the Broward County School District. MATERIAL ALLEGATIONS 3. During the 2007 - 2008 school year, the Respondent engaged in inappropriate conduct towards S.R., a sixteen year-old female student. Specifically: (a) the Respondent discussed with S.R. whether S.R. was a virgin, (b) the Respondent commented on S.R.’s physical appearance, including that she was a “very beautiful girl” and “had big lips and a big booty,” JONATHAN MATTHEW LOWNDES Administrative Complaint Page 2 of 4 (c) the Respondent told S.R. that ifhe were sixteen years old, he would ask S.R. out and that ifS.R. were twenty years old the Respondent would have “tried something;” and ; . (d) the Respondent asked S.R. not to tell anyone about his comments. 4, During May of 2008, the Respondent engaged in inappropriate conduct towards B.W., a seventeen year-old female student. Specifically: (a) B.W. approached the Respondent about being a teaching assistant in his class for the following year. The Respondent had B.W. stay during a class period to discuss the request. During the conversation, the Respondent asked B.W. if she was a virgin and if she had performed any sexual acts; (b) the Respondent asked B.W. why she was going to wait until marriage before losing her virginity; (c) the Respondent told B.W. that he lost his virginity to a teachers assistant when the Respondent was fourteen years old; (d) the Respondent offered to perform sexual acts on B.W.; {e) the Respondent told B.W. that his wife allowed him to have sex with other women; (f) the Respondent asked B.W. to stay after all of the other students had left the classroom; (g) the Respondent hugged B.W., kissed her on the neck using his tongue, and asked her if she liked it; (h) the Respondent later asked B.W. not to tell anyone about his conduct and told B.W. that he acted like a seventeen year-old boy towards B.W.; and (i) the Respondent showed B.W. an image of a naked adult female on his classroom computer. 5. During the 2007 - 2008 school year, the Respondent engaged in inappropriate conduct towards S.D., a fifteen year-old female student. Specifically, (a) the Respondent asked S.D. how big her breasts were and if she were wearing any undergarments; ‘JONATHAN MATTHEW LOWNDES Administrative Complaint Page 3 of 4 (b) the Respondent took S.D. into a storage closet, asked S.D. to pull down her pants, and the Respondent touched S.D.’s breasts and undergarments; and (c) the Respondent asked S.D. not to tell anyone about his conduct. 6. During the 2007 - 2008 school year made inappropriate comments to students in his classes. Specifically, the Respondent (a) told students that he had slept with their mothers; and (b) told students that “when you go home, you can pick up my boxer shorts in your Mom's room.” 7. On or about February 18, 2009, the School District of Broward County notified the Respondent that it intended to terminate his employment for immorality, moral turpitude and misconduct in office, based upon the conduct alleged in Paragraphs 3, 4, and 6 of this Administrative Complaint. 8. On or about February 27, 2009, the Respondent resigned from his position with the School District of Broward County. 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 schooi board. COUNT3: The Respondent is in violation of Section 1012.795(1 )G), 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. JONATHAN MATTHEW LOWNDES Administrative Complaint Page 4 of 4 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 ora 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 and day of Foo UU L , 2010. Commissioner of Education State of Florida

Docket for Case No: 10-010518PL