STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, VS. CASE NO. 090-2703 PAUL MATTHEW LIOTTI, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against PAUL MATTHEW LIOTTI. 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 L. The Respondent holds Florida Educator’s Certificate 1033996, covering the area of Social Science, which is valid through June 30, 2014. 2. At all times pertinent hereto, the Respondent was employed as a Social Science Teacher at South Plantation High School in the Broward County School District. MATERTAL ALLEGATIONS 3. On or about April 26, 2010, in a hotel room in New York City, Respondent engaged ina physical altercation with an adult female in the presence ofa five-year old child. The altercation resulted in physical injury to the adult female, including extreme swelling and bleeding of the face. As aresult of Respondent's involvement in the April 26, 2010 altercation, Respondent was arrested. and charged with multiple criminal counts. On or about May 6, 2010, Respondent was placed on administrative leave by the School Board of Broward County. On or about June 16, 2010, in the Criminal Court of the City of New York, County of New York, Respondent pled guilty and was adjudicated guilty of one count of Aggravated Criminal Contempt. PAUL MATTHEW LIOTTI Administrative Complaint Page 2 of 3 4, On or about October 25, 2011, in Broward County, Florida, Respondent operated a vehicle while under the influence of alcohol. Respondent was arrested and charged with Driving Under the Influence. Applicant refused a breath test. On or about February 22, 2012, in the County Court of the Seventeenth Judicial Circuit, In and For Broward County, State of Florida, Respondent pled no contest to and was adjudicated guilty of Driving Under the Influence. 5. Respondent failed to self-report to district authorities with 48 hours of entering a plea of no contest and/or the adjudication. 6. Pursuant to Section 1012.795(2), Florida Statutes, the plea of guilty or the decision of guilty by a court is prima facie proof of grounds for revocation or other sanctions. 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)(f), Florida Statutes, in that Respondent has been convicted or found guilty of, or entered a plea of guilty to, regardless of adjudication of guilt, a misdemeanor, felony, or any other criminal charge, other than a minor traffic violation. COUNT :3 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. COUNT 4: The Respondent is in 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 5: The Respondent is in violation of Rule 6B-1.006(5)(n), Florida Administrative Code, in that Respondent has failed to self-report within forty-eight (48) hours to appropriate authorities (as determined by district) any arrests/charges involving the abuse ofa child or the sale and/or possession of a controlled substance. Such notice shall not be considered an admission of guilt nor shall such notice be admissible for any purpose in any proceeding, civil or criminal, administrative or judicial, investigatory or adjudicatory. In addition, Respondent shall self-report any conviction, finding of guilt, withholding of adjudication, commitment to a pretrial diversion program, or entering ofa plea of guilty or Nolo Contendere for any criminal offense other PAUL MATTHEW LIOTTI Administrative Complaint Page 3 of 3 than a minor traffic violation within forty-eight (48) hours after the final judgment. When handling sealed and expungéd records disclosed under this rule, school districts shall comply with the confidentiality provisions of Sections 943.0585(4)(c) and 943.059(4)(c), Florida Statutes. 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 2. ] =~" day of October __, 2012, PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 13-002115PL