STATE OF FLORIDA EDUCATION PRACTICES COMMISSION GERARD ROBINSON, as Commissioner of Education, Petitioner, vs. CASE NO. 056-2620-W KENNETH BRETT BANKSTON, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Gerard Robinson, as Commissioner of Education, files this Administrative Complaint against KENNETH BRETT BANKSTON. 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: TURISDICTION lL. The Respondent holds Florida Educator’s Certificate 824910, covering the areas of Educational Leadership, Speech and Exceptional Student Education, which is valid through June 30, 2013. 2. Atall times pertinent hereto, the Respondent was employed as a Computer Education Teacher at Charles Drew Middle School in the Miami-Dade County School District. MATERIAL ALLEGATIONS 3, During the summer of 2003, Respondent fraudulently obtained college credits from Eastern Oklahoma State College (ZOSC) through the Moving On Toward Education and Training (MOTET) program, without availing himself of actual academic class time, work, or effort. 4, On or about July 15, 2003, Respondent submitted a transcript from Eastern Oklahoma State College (EOSC) to the Florida Department of Education. The transcript was used to fulfill professional preparation requirements for the issuance ofa professional educator certificate. Filed November 27, 2012 1:48 PM Division of Administrative Hearings KENNETH BRETT BANKSTON Administrative Complaint Page 2 of 3 The professional certificate was issued to Respondent on or about November 13, 2003. The MOTET courses required no work or a minimal amount of work or academic effort, and Respondent knew or should have known that the courses were not sufficient to satisfy requirements for a Florida educator’s certificate. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1)(a), Florida Statutes, in that Respondent obtained or attempted to obtain a teaching certificate by fraudulent means, COUNT2: 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 rules. RULE VIOLATIONS COUNT 3: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(5)(a), Florida Administrative Code, in that Respondent has failed to maintain honesty in all professional dealings. COUNT4: The Respondent is in violation ofRule 6B-1.006(5)(g), Florida Administrative Code, in that Respondent has misrepresented his professional qualifications, COUNTS: The Respondentis in violation of Rule 6B-1.006(5)(h), Florida Administrative Code, in that Respondent has submitted fraudulent information on a document in connection with professional activities. (SIGNATURE ON FOLLOWING PAGE) KENNETH BRETT BANKSTON 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. Commissioner of Education State of Florida

Docket for Case No: 12-003854PL