STATE OF FLORIDA

.EDUCATIONPRACTICES COMMISSION

DR. ERIC J. SMITH, as

Commissioner of Education,

Petitioner,

vs. CASE NO. 089-2831

RICKY WOODS,

Respondent.

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ADMJNISTRA TIVE COMPLAINT

Petitioner, :Or. Eric J. Smith, as Commissioner of Education, files this Administrative Complaint against RICKY WOODS. The Petitiot1et seeks the appropriate disciplinary sanction of tlie 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

l. The Respondent holds Florida Educator's Certificate 518320, covering the area of Elementary Education, which is valid through June 30, 2012.

1. At all times pertinent hereto, the Respondent was employed as a Kindergarten

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   MATERIAL ALLEGATIONS

   
   

2. During the 2008-2009 school year, the Respondent engaged in inappropriate conduct towards students. Specifically:

   
   

   1. On or about January 28, 2009, B.W., a five year-old male student, engaged in an altercation with another student. The Respondent grabbed B.W. by the front of B.W.'s shirt and pulled B.W. back and forth several times, striking B.W. on the chest and telling B.W. to "fight me instead," or words to that effect;

      
      

      Filed March 7, 2011 4:25 PM Division of Administrative Hearings

      RICKY WOODS

      Administrative Complaint

      Page 2 of3

      
      

   2. On or about February 3, 2009, J.C., a six year-old male student, went down a playground slide after previously having been directed not to. When J.C. came to the bottom of the slide, the Respondent grabbed J.C. by his jacket and pushed or threw

      J.C. to the ground;

      
      

   3. The Respondent struck J.C. with a mler; and

      
      

   4. The Respondent pushed students into the timeout chair and grabbed them by their anns to redirect their behavior.

The Petitioner charges:

STATUTE VIOLATIONS

COUNT 1: The Respondent is in violation of Section 1012.795(1)(j), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession prescribed by State Board of Education mles.

RULE VIOLATIONS

COUNT 2: 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 3: The allegations of misconduct set forth herein are in violation of Rule 6B- l.006(3)(e), Florida Administrative Code, in that Respondent has intentionally exposed a student to unnecessary embarrassment or disparagement.

(SIGNAT1JRE ON FOLLOWING PAGE)

RICKY WOODS

Administrative Complaint

Page 3 of3

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; detennining 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 l O years or pennanently.

EXECUTED on this

nL7+-\

day of

"L',-X.:-I ;J:;Q.../ , 2010.

State ofFlorida

Docket for Case No: 11-001161PL