BEFORE THE SCHOOL BOARD OF BROWARD COUNTY, FLORIDA ROBERT W. RUNCIE, Superintendent, Petitioner, vs. KARL RICHARDS, Respondent. ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, THE SCHOOL BOARD OF BROWARD COUNTY, FLORIDA, through its Superintendent ROBERT W. RUNCIE, and files this Administrative Complaint and states the following: I, JURISDICTIONAL BASIS 1, The Agency is The School Board of Broward County, Florida located at 600 Southeast Third Avenue, Fort Lauderdale, Broward County, Florida 33301. 2. The Petitioner is Robert W. Runcie, who is the Superintendent of Schools of Broward County, Florida, His address is 600 Southeast Third Avenue, Fort Lauderdale, Broward County, Florida 33301. 3, The Petitioner is statutorily obligated to recommend the placement of School Board personnel, and require compliance and observance by all personnel with all laws, rules and regulations, See §1012.27, Fla, Stat. 4, The employee against whom termination is recommended, Respondent, Karl Richards, has been employed by The School Board of Broward County, Florida, since 2008, with his last known employment as a music teacher at Parkway Middle School. The last known address of the Respondent, is 6140 N.W. 32 Way, Ft, Lauderdale, PL 33309. 5. The legal basis for Mr. Richards’ termination is immorality and misconduct in office. See §1012.33(1)(a), (4)(c), (6)(b), Fla. Stat. See also Fla. Admin. Code r. 6A-5.056; 6B-1.001, 6B-1,006, 6B-4.009. I. ADMINISTRATIVE CHARGES The Petitioner, Robert W. Runcie, alleges as follows: 6, This recommendation for termination from employment is based on allegations that Mr. Richards engaged in an inappropriate relationship. with a minor student. 7. In December 2011, a parent reported to Parkway Middle School that Mr. Richards had been sending inappropriate, sexually suggestive text messages to his son via cellular telephone. 8. Principal Bradford Mattair requested a personnel investigation, and the matter was investigated by Kathleen Andersen from Professional Standards & Special Investigative Unit. 9. The matter was also reported to the Hollywood Police Department, which determined that although some of the text messages were inappropriate, the content did not meet the level required to support criminal charges. 10. The SIU investigator, Kathleen Andersen, was able to recover text messages between the teacher and the student (RF) between August and December 2011, 11. During that time frame, in excess of 1,000 text messages were exchanged. - 12. Mr. Richards met the student, RF, when he was a sixth-grade student at Parkway Middle School in approximately 2009-2010, when Mr. Richards was RF’s music/piano teacher. 13. The texts at issue in this case were recovered several years later, when RF was a fifteen year old, ninth-grade student at Dillard High School. 14. The two continued a friendship over the years, and on several occasions, with RF’s parents’ permission, Mr, Richards picked RF up from school and his home for concerts or meals. 15. A review of the text messages from the 2011 time frame shows that the teacher and the minor student engaged in conversations about relationships, sexuality (including Mr. Richards’ bi-sexuality), emotions, sexual experiences and infidelity. 16.° Some of the text messages sent by Mr. Richards were sexually suggestive, and others implied that Mr. Richards intended to purchase gifts for RF, | 17. . In some of the texts messages, RE, distraught over breaking up with a girlfriend, claimed that he intended to commit suicide. - 18, Mr. Richards never reported those suicidal threats to anyone at any time. 19, In October 2011, RF’s father found some text messages and contacted Mr, Richards, by phone, and told the teacher to have no further contact with RF. 20. Mr. Richards then stopped all communication for several months, but started up again in December 2011. 21. Shortly thereafter, RF’s father again found the text messages that had been exchanged, and sent a text to Mr. Richards advising him not to contact RF. The father also contacted the school 3 and authorities. 22, The matter went before the Professional Standards Committee on June 6, 2012; the Professional Standards Committee found probable cause and recommended that Mr. Richards be terminated from employment. 23. A pre-disciplinary meeting was held on June 25, 2012. 24. Having reviewed the materials supporting the charges against Mr. Richards, including the full investigative report and documentation, the Petitioner/Superintendent hereby agrees with the recommendation of the Professional Standards Committee and recommends, to the School Board of Broward County, that Mr. Richards be terminated from his employment. 25. In accordance with Florida law, this recommendation for termination must be reviewed, and approved by the School Board. See §1012.33(6)(b), Fla, Stat, 26. If the ultimate decision is adverse to him, Mr, Richards may challenge the decision by seeking an administrative hearing pursuant to Chapter 120 of the Florida Statutes. a EXECUTED this. day of ae 2012, ROBERT W, RUNCIE Superintendent of Schools

Docket for Case No: 12-002831TTS