STATE OF FLORIDA EDUCATION PRACTICES COMMISSION DR. ERIC J. SMITH, as Commissioner of Education, Petitioner, vs. CASE NO. 090-2714 ADAM J. BRUNO, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Dr. Eric J. Smith, as Commissioner of Education, files this Administrative Complaint against ADAM J. BRUNO. 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 1048776, covering the areas of English and Exceptional Student Education, which is valid through June 30, 2011. 2. At all times pertinent hereto, the Respondent was employed as an English Teacher t Riverdale High School in the Lee County School District. MATERIAL ALLEGATIONS 3. During the Spring of the 2009-2010 school year, the Respondent engaged in a romantic relationship with A.W., a female student who was seventeen years old when the relationship began. Specifically: (a) the Respondent told A.W. that he had feelings for her; (b) the Respondent told A.W. that he wanted to have a more intimate relationship with A.W. afier she graduated from high school; Filed September 28, 2011 2:18 PM Division of Administrative Hearings ADAM J. BRUNO Administrative Complaint Page 2 of 3 (c) the Respondent and A.W. exchanged frequent text messages, including approximately 14006 text messages from April 21, 2016 to May 1, 2010; (d) the Respondent frequently spoke with A.W. on the telephone, including approximately 138 hours of phone calls from March 21, 2010, to May 1, 2010; (e) the Respondent gave gifts to A.W., including his t-shirts and a neck-tie; and (f) the Respondent hugged A.W. on several occasions. 4. On or about May 3, 2010, the Lee County School District suspended the Respondent from his position. 5. On or about June 1, 2010, the Respondent’s employment contract with the Lee County School district expired. 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 isin violation of Section 1012.795(1)(), 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. 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. ADAM J. BRUNO Administrative Complaint Page 3 of 3 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 \ oth day of Noes { , 2011, ssioner of Education State of Florida

Docket for Case No: 11-005027PL