THE STATE OF FLORIDA

THE SCHOOL BOARD OF MONROE COUNTY, FLORIDA

Dr. JOSEPH P. BURKE,

Superintendent of Schools,

Petitioner,

V.

Philip Steadham,

Respondent.

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ADMINISTRATIVE COMPLAINT

Petitioner, Dr. JOSEPH P. BURKE, Superintendent of Schools of Monroe County, Florida, files this Administrative Complaint, pursuant to Chapters 120, 1001 and 1012, Florida Statutes (2003), Rules 68-1.001, and 68-1.006, Florida Administrative Code, and the Policies of the School District of Monroe County, Florida and states as follows:

JURISDICTIONAL BASIS

1. The agency is The School Board of Monroe County, Florida, located at 241 Trumbo Road, Key West, Florida 33040.

2. The Petitioner, Dr. JOSEPH P. BURKE, is the Superintendent of Schools of Monroe County, Florida. His address is 241 Trumbo Road, Key West, Florida 33040.

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3. The Petitioner is statutorily obligated to recommend the placement of all school personnel and to require all employees to observe and comply with all laws, rules and regulations. Petitioner is required by law to report and recommend appropriate action against any school employee who fails to comply therewith, inclusive of the Respondent, Philip Steadham.

4. The Respondent, Philip Steadham, is an employee of the School Board of Monroe County, Florida, and is currently employed as an Exceptional Student Education teacher.

5. The last known address of the Respondent, Philip Steadham, is 1236, 51st Street Gulf, Marathon Florida, 33050.

   
   

   ADMINISTRATIVE CHARGES

   
   

   Petitioner, DR. JOSEPH P. BURKE, re-alleges the above and states as follows:

   
   

6. At all times pertinent hereto, the Respondent was employed as a Exceptional Student Education teacher at Marathon High School in t+,e Monroe County

   School District.

   
   

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7. On several occasions between June of 2010 and October 251

   
   

   2010,

   
   

   respondent engaged in physical rough housing and ear pulling of students.

   
   

8. Additionally, Respondent engaged in disparaging nick naming of students during this timeframe as well as embarrassing name calling and classroom displays.

   
   

9. The above conduct constitutes violations of School Board Policies 1.001, the Code of Ethics for the Education Profession in Florida, 68 - 1.001, and Principles of Professional Conduct for the Education Profession 68-1.006

10. On December 1ih, 2010, Respondent and or his attorney requested in

    writing a hearing to challenge the termination of Respondent, the Honorable Patricia M. Hart issued an Order Requiring Filing of Specific Charges, which Petitioner hereby files pursuant to an agreed motion for extension.

    
    

    DEMAND FOR RELIEF

    
    

11. Petitioner, DR JOSEPH P. BURKE, Superintendent of Schools of Monroe County, Florida recommends that the Monroe County School Board, after providing the requisite notice, suspend the Respondent, Philip Steadham, from his employment as an employee, for (10) ten days without pay, predicated upon the foregoing facts and legal

authority.

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EXECUTED this

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;::;---day of /'f/7 .; ,2011.

                    PHP.BURKE

Superintendent of Schools

STATE OF FLORIDA )

) SS: COUNTY OF MONROE )

BEFORE ME, the undersigned authority, personally appeared, DR JOSEPH P. BURKE, to be known to be the person described in the foregoing instrument; and he

acknowledged that he executed the foregoing instrument for the purpose therein contained.

WITNESS my hand and seal this j_ day of 01tt'1(Al\v , 2011.

NOTARY PUBLIC, STATE OF FLORIDA

My Commission Expires:

CERTIFICATE OF SERVICE

Mz

Personnel,

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I HEREBY CERTIFY that a copy of this document has been furnished to Philip Steadham, Via Counsel, Mark Herdman at Herdman and Sakellarides, P.A. 29605 U.S. Highway19 North, Suite 110 Clearwater, FL. 33761, Leon Fowler United Teachers of Monroe 1400 United Street, #105 Key West, FL 33040 and Cheryl Allen, Director of

by mail this day of

        <l/\ , 2011. . 0

County School Board, 241 Trumbo Road, Key West, Florida 33040,

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. 11518

School Board Attorney

Docket for Case No: 11-000087TTS