STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 112-1743 KARL V. RICHARDS, Respondent. ADMINISTRATIVE COMPLAINT. Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint “against KARL V. RICHARDS. 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 I. The Respondent holds Florida Educator’s Certificate 1107422, covering the area of - Music, which is valid through Jume 30, 2016: 2. At all times pertinent hereto, the Respondent was employed as a Music Teacher at Parkway Middle School in the Broward County School District. MATERIAL ALLEGATIONS 3. From September through December of 2011, the Respondent exchanged several bundred text messages with 15 year-old male student R.F. The Respondent cultivated a personal relationship with R.P. that exceeded the boundaries ofa student-teacher relationship. Specifically: (a) the Respondent and R.F. discussed their personal lives; (b) the Respondent discussed whether he was attracted to R.F.; KARL V. RICHARDS Administrative Complaint Page 2 of 3 (c) the Respondent asked R.F. if he had ever had an experience with the same sex; (d) when R.F. expressed emotional distress and discussed suicide, the Respondent did not report R.F.’s comments to appropriate authorities; (e) the Respondent toid R.F. that he had to wait until R.F. turned 18 years-old before the Respondent could tell him about “sexual things;” and (f) after R.F.’s father discovered the text messages between R.F. and the Respondent, R.F.’s father advised the Respondent not to contact R.F. The Respondent continued to communicate with RF. 4, On or about December 14, 2011, the Broward County School District placed. the Respondent on administrative reassignment. 5. On or about August 7, 2012, the Broward County School District notified the Respondent of its intent to terminate the Respondent’s employment. 6. The Respondent’s conduct with respect to R.F, and the school district’s intent to terminate the Respondent was reported in local news media,’ 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 hasbeen found guilty of personal conduct which seriously reduces his effectiveness as an employee of the school board. COUNT3: The Respondent is in violation of Section 1012.795(1)q), 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. KARL V. RICHARDS Administrative Complaint Page 3 of 3 COUNTS: 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. 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 yeais 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 yor day ot Novewnloer 2012. May t breerf PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 13-001366PL