STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, VS. CASE NO. 112-2902 ROSS JAMES PEGLER, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against ROSS JAMES PEGLER. The Petitioner seeks the appropriate disciplinary sanction of the Respondent's educator’s certificate pursuantto 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 1. The Respondent holds Florida Educator’s Certificate 644059, covering the areas of English for Speakers of Other Languages (ESOL), History and Exceptional Student Education, which is valid through June 30, 2015. 2. At all times pertinent hereto, the Respondent was employed as an Exceptional Student Education Teacher at Royal Palm Exceptional Center School in the Lee County School District. MATERIAL ALLEGATIONS 3, On or about April 20, 2012, Respondent physically assaulted S.R., a 13+year-old, male student after S.R. tapped Respondent on the shoulder. Respondent grabbed S.R. by the hood of his jacket and pushed him against a wall, While holding S.R. against the wall, Respondent struck & R. in the face with his elbow causing S.R. to sustain a split lip. Subsequently, when S.R. walked back past Respondent, Respondent stated to S.R., "Tf you touch.me again, I will put you in jail," or words to that effect. ROSS JAMES PEGLER. Administrative Complaint Page 2 of 3 4, On or about July 17, 2012, Respondent was suspended by the District for a period of twenty (20) days as a result of his attack of S.R. 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 has been found guilty of personal conduct which seriously reduces his effectiveness as ari employee of the school board. ; COUNT3: The Respondentis 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. ULE VIOLATIONS COUNT 4; The allegations of misconduct set forth herein are in violation of Rule 6A- 10,08 1(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. COUNT 5: The allegations of misconduct set forth herein are in violation of Rule 6A~ 10.081(3)(e), Florida Administrative Code, in that Respondent has intentionally exposed a student to unnecessary embarrassment or disparagement. (SIGNATURE ON FOLLOWING PAGE) ROSS JAMES PEGLER 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 ahd 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 ora 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; ditecting 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 T*2_ aayor November, 2013. PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 14-001760PL