STATE OF FLORID EDUCATION PRACTICES COMMISSION DR. TONY BENNETT, as Commissioner of Education, Petitioner, Vs. CASE NO, 112-0023 CURTIS BROWN, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Dr. Tony Bennett, as Commissioner of Education, files this Administrative Complaint against CURTIS BROWN. 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 6A-10.081, 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 963479, covering the areas of Reading and Exceptional Student Education, which is valid through June 30, 2017. 2. At all times pertinent hereto, the Respondent was employed as an Exceptional Student Education Teacher at Miami Southridge Senior High School in the Miami-Dade County School District. : MATERIAL ALLEGATIONS 3, On or about July 15, 2007, in Miami-Dade County, Florida, the Respondent was arrested and charged with Unlawful Possession of Cannabis. 4, The Respondent did not report his July 15, 2007, arrest for Unlawful Possession of Cannabis to school district officials within 48 hours of the arrest. CURTIS BROWN Administrative Complaint Page 2 of 3 5. On or about July 18, 2010, in Miami-Dade County, Florida, the Respondent discovered that an individual had left a debit card in an Automatic Teller Machine. The Respondent withdrew $300.00 from the individual’s account without the individual’s consent. The Respondent was arrested and charged with Third Degree Grand Theft and Fraudulent Use ofa Credit Card. On or about September 16, 2010, the Respondent entered into a pre-trial advocate program and the charges were later nolle prossed. 6. The Respondent did not report his September 16, 2010 entry into the pre-trial advocate program for Third Degree Grand Theft and Fraudulent Use of a Credit Card to school district officials within 48 hours. 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. COUNT2: The Respondentis in violation of Section 1012.795(1)G), 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 Respondent is in violation of Rule 6A-10.08 1(5)(m), 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 of a plea of guilty or Nolo Contendere for any criminal offense other than a minor traffic violation within forty-eight (48) hours after the final jud igment. When handling sealed and expunged 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. (SIGNATURE ON FOLLOWING PAGE) CURTIS BROWN 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 inthe 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 permaneritly. EXECUTED on this ZLg*? day of _(Y\gur. ch 2013. DR. TONY BENNETT as Commissioner of Education State of Florida

Docket for Case No: 14-001053PL