THE SCHOOL BOARD OF BROWARD COUNTY, FLORIDA ROBERT W. RUNCIE, Superintendent of Schools, Petitioner, PETITION FOR FORMAL PROCEEDINGS Vv. SCHANDRA RODRIGUEZ-CONTI, Respondent. / ADMINISTRATIVE COMPLAINT sn ERATIVE COMPLAINT Petitioner, Robert W. Runcie, Superintendent of Schools of Broward County, Florida, through his undersigned counsel, Law Offices of Carmen Rodriguez, P.A., files this Administrative Complaint, pursuant to Chapters 120, 1001, and 1012 of the Florida Statutes, as well as Chapters 6B-1 and 6B-4 of the Florida Administrative Code, and states the following: 1. Jurisdictional Basis a. The agency is the School Board of Broward County, Florida, located at 600 Southeast Third Avenue, Fort Lauderdale, Broward County, Florida 33301. b. The Petitioner is Robert W. Runcie, who is the Superintendent of Schools of Broward County, Florida. ; i c. The Petitioner is statutorily obligated to recommend the placement of school personnel and to require compliance and observance with all laws, rules, and regulations. Any violation thereof shall be reported with the appropriate disciplinary action against any school personnel failing to comply therewith, inclusive of the Respondent, Schandra Rodriguez-Conti (hereinafter “Rodriguez-Conti”). d. Respondent Rodriguez-Conti is an employee of the Broward County School Board and is currently employed as a teacher at Blanche Ely High School. e. The last known address of the Respondent, Schandra Rodriguez-Conti, is 1780 S.W. 25" Avenue, Fort Lauderdale, Florida 33312. 2; Specific Charges The Petitioner Robert W. Runcie, alleges as follows: a. Respondent has shown a gross disregard for directives relating to course curriculum and teaching methods. Respondent has continuously ignored directives to teach materials consistent with established and approved course curriculum and to refrain from teaching materials and methods which were specifically disapproved. Furthermore, Respondent failed to instruct and grade students? course work consistent with instructional guidelines and fairness, and has failed to provide any feedback to students on their work assignments. More specifically: b. On or about August 30, 2011, Respondent had a conference to discuss Audiovisual Material Use Policy. Respondent admitted at the conference that she had shown videos that were a part of the Rodriguez Test-Tagging Method (“RTTM”) and were not approved by administrators prior to showing the video. Respondent also admittedly failed to send home an approved Alternate Assignment form or Full-length Feature Films To Be Used For Classroom Instruction form. Respondent was told that videos must be approved and parents must be notified prior to showing them in the classroom. (oy On or about September 14, 2011, Respondent Rodriguez-Conti, was observed in the classroom teaching via the RTTM method which she was told is not an approved method by the district or the state. Respondent did not use appropriate curriculum materials for the course she was teaching. The students did not understand Respondent’s lessons as her directions were very unclear. Respondent was observed teaching information that was not consistent with the required curriculum. Respondent failed to teach required literary works. On September 16, 2011, Respondent was provided the district’s unit plans for both of Respondent’s English courses and provided a set of textbooks and interactive readers for both courses. d. On September 30, 2011, Respondent was provided a pre-disciplinary meeting regarding inappropriate comments and actions toward her students. Specifically, Respondent told students in her classroom to “shut up” and did not permit a student into her classroom, even though the student had a pass from the Assistant Principal. Respondent failed to use appropriate measures to handle her students’ discipline and failed to follow protocol regarding the district’s referral system. Respondent was counseled to use appropriate measures when handling students’ discipline. e. On or about October 14, 201 1, Respondent’s students were observed working on make-up work and other students were looking at a laptop discussing hair styles and outfits. One student was observed completing a RTTM dictation packet. Again, Respondent was observed teaching information that was not consistent with the required curriculum. Furthermore, Respondent did not provide students with feedback on assignments because she kept them in a locked file cabinet. On October 17, 2011, Respondent was again ordered to refrain from using the RTTM method and was provided an email from the area director stating that the RTTM model is not an approved method by the district and ordering that this method not be taught. f. On or about October 17, 2011, Respondent’s parent conference was observed and it was noted that a student was failing. Respondent’s students were assigned work that was not assessed fairly. Respondent also assigned too many assignments for the students in a one week period. Respondent was told she would continue to receive assistance in Instructional Planning, Lesson Presentation, Subject Matter, and Student Performance. g. On November 10, 2011, Respondent’s classroom was observed again. During the observation, it was noted that the light was off and the room was dark. Respondent failed to provide her students with clear learning objectives that connected to the work the students must complete. Respondent was noted that she failed to plan lessons effectively. One student was observed with her head on her desk. When Respondent assisted the student, she spoke to her in Spanish. Respondent also spoke to the ESOL paraprofessional in Spanish. Respondent was provided ESOL strategies to assist Respondent in planning more effective lessons. Respondent was told she would continue to receive assistance in Instructional Planning, Lesson Presentation, Subject Matter, and Student Performance. h. On or about December 13, 2011, Respondent stated to the Assistant Principal that despite her students not performing or behaving well in her class, she refused to hold any parent conferences. Respondent told the Assistant Principal: “you can meet with the parents and let me know what happens.” 1: On January 13, 2012, Respondent was observed without most of her students present in the classroom. Respondent stated to the Assistant Principal that the students were out of class returning books, which was against school procedure. Students were found wandering the campus in various locations. Respondent was observed in the classroom asking other students to identify states on a map of the United States, which was clearly not aligned with the required curriculum. Other students were not given any work to complete. Some students were observed on the Internet checking email and engaging in conversation not relating to any curriculum objectives. I On January 17, 2012, Respondent’s classroom was observed again with very few students present. When asked what the students were doing in the classroom today, Respondent replied that the students were doing nothing. Respondent was told she would continue to receive assistance in Instructional Planning, Lesson Presentation, Subject Matter, and Student Performance and that she would be assisted by the Reading Coaches in planning and presenting lessons. k. Respondent was issued a written reprimand for her insubordination on J anuary 18, 2012, for refusing to conduct parent conferences. I; On January 18, 2012, Respondent was issued another written reprimand for insubordination for continuously refusing to read and teach the required literary works in the curriculum. m. Respondent’s manner of assessing students’ work was a concern. The Assistant Principal instructed Respondent at her pre-disciplinary meeting on January 23, 2012 to provide student work for the Assistant Principal to review. n. On January 25, 2012, Respondent sent an email refusing to provide any samples of her students’ work: “Dear Ms. Baugh, I will not submit any student samples at this time. Sincerely, Schandra Rodriguez-Conti.” Respondent was observed placing a box of papers into her car. 0. On February 8, 2012, Respondent’s classroom was observed with the lights out and an unapproved movie being shown to students. Respondent has refused to meet regarding a post-observation conference. 3. Just Cause Just cause exists for the requested relief pursuant to § 1012.33 Fla. Stat., the Respondent’s employment contract, School Board rules and regulations, the Code of Ethics of the Education Profession, and the Employee Disciplinary Guidelines promulgated by the School Board, including but not limited to the following: a. Gross insubordination or willful neglect of duties: The Respondent, through her above-described conduct, violated § 1012.33 Fla. Stat., and Rule 6B-4.009(4) of the Florida Administrative Code, and her actions constitute a constant or continuing intentional refusal to obey a direct order, reasonable in nature, and given by and with proper authority. Additionally, the Respondent’s above-described conduct further violates the Code of Ethics of the Education Profession, Rule 6B-1.001, 6B-1.006, Florida Administrative Code. The Respondent’s conduct, as factually set forth herein, is sufficiently notorious to bring the Respondent and/or the education profession into public disgrace or disrespect and impair the Respondent’s service in the community. The Respondent also intentionally suppressed and distorted subject matter relevant to a student’s academic program and failed to make reasonable efforts to protect students from conditions harmful to learning. b. Incompetency: The Respondent, through her above-described conduct, violated § 1012.33 Fla. Stat., and Rule 6B-4.009(1)(a) of the Florida Administrative Code, and her actions show an inability to discharge the required duty as a result of inefficiency. Respondent’s actions constitute repeated failure on the part of Respondent to teach, instruct, grade students’ course work, communicate with and relate to children in the classroom, to such an extent that pupils are deprived of minimum educational experience. Additionally, the Respondent’s above-described conduct further violates the Code of Ethics of the Education Profession, Rule 6B-1.001, 6B-1.006, Florida Administrative Code. The Respondent’s conduct, as factually set forth herein, is sufficiently notorious to bring the Respondent and/or the education profession into public disgrace or disrespect and impair the Respondent’s service in the community. The Respondent also intentionally suppressed and distorted subject matter relevant to a student’s academic program and failed to make reasonable efforts to protect students from conditions harmful to learning. WHEREFORE, based upon the foregoing, the Petitioner, Robert W. Runcie, Superintendent of Schools, recommends that the School Board, subsequent to providing requisite notice, terminate the Respondent, Schandra Rodriguez-Conti, from her employment based upon the foregoing facts and legal authority. Dated: March dQ, 2012 Robert W. Runcie, Superintendent of Schools Respectfully submitted: Carmen Rodriguez, Esquire Cadre Attorney

Docket for Case No: 12-001859TTS