STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, VS. CASE NO. 101-2890 RANDY CORINTHIAN, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against RANDY CORINTHIAN. 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 884442, covering the.area of Music, which is‘valid through June 30, 2015. 2. At all times pertinent hereto, the Respondent was employed as a Band Teacher at Boyd H. Anderson High School and a Music Teacher at Parkway Middle School in the Broward County Schoo! District. MATERIAL ALLEGATIONS 3. During the 2010-2011 school year, while employed as a teacher at Boyd Anderson High School, Respondent used his school issued laptop to receive and save personal emails, including images of men and women in sexually provocative poses and emails regarding his private business venture related to booking musical performances. RANDY CORINTHIAN Administrative Complaint Page 2 of 3 4, During October of 2011, the Broward County School District issued Respondent a Letter of Reprimand for his misuse of the school issued laptop as alleged in paragraph 3 of this Administrative Complaint. 5. On multiple occasions during the 2011-2012 school year, while employed as a teacher at Parkway Middle School, Respondent disciplined students inappropriately by flicking students in the head or ear with his finger, placing students in headlocks, and grabbing students roughly by the arm, or conduct of a similar nature. 6. On or about April 9, 2013, as a result of the conduct alleged herein, the Broward County School District terminated Respondents employment. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: 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 effectiveness as an employee of the school board. COUNT 2: The Respondent is 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 allegations of misconduct set forth herein are in violation of Rule 6A~ 10.081(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 4: — 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. COUNT 5: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(4)(c), Florida Administrative Code, in that Respondent has used institutional privileges for personal gain or advantage, (SIGNATURE ON FOLLOWING PAGE) RANDY CORINTHIAN 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 Hmited 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 /4%% day of Avgust , 2014. PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 15-000955PL