STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 123-1255 JEAN-BAPTISTE MONTFORT GUERRIER, Respondent. ADMINISTRATIVE COMPLAINT Pétitioner, Pam Stewart, as Commissioner of Education, files this Adininistrative Complaint against JEAN-BAPTISTE MONTFORT GUERRIER. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educatot’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 Edticator’s Certificate 596926, covering the.areas of English and Middle Grades, which is valid through June 30, 2015. 2. At all times pertinent hereto, the Respondent was employed as a Vocational Education Teacher at D.A. Dorsey Education Center School in the. Miami-Dade County School District. MATERIAL ALLEGATIONS 3. Between August 2011 and August 2012, on school grounds Respondent engaged in the following inappropriate behavior: (a) making inappropriate remarks to 25-year-old female student D.W., such as,“Let me.see the pussy. How good is it?” and, “What would you do.for a grade?” or words to that effect; JEAN-BAPTISTE MONTFORT GUERRIER Administrative Complaint Page 2 of 3 {b) pulling the underwear of 17-year-old female student K. L., rubbing K.L.’s stomach, asking K.L. if he could lick her belly ting, asking K.L. when she was going to turn 18 years old and telling KL. that she is “only good at throwing that pussy around,” or words to that effect; (c) pulling the underwear of 17-year-old female student G. C.; and (d) conducting inappropriate conversations with his class on the topic of ‘Sex, 4 On or about October 5, 2012, the Miami-Dade school district notified Respondent that he would be recommended for suspension without pay and dismissal. 5. On or about October 8, 2012, Respondent submitted his resignation for his position at the Miami-Dade school district. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: — The Respondent is in violation of Section 1012.795(1)(d), Florida Statutes, in that Responderit 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 an employee of the school board. COUNT3: 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 4: 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 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. JEAN-BAPTISTE MONTFORT GUERRIER, Administrative Complaint Page 3 of 3 COUNT 6: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.0813)(h), Florida Administrative Code, in that Respondent has exploited a relationship witha student.for personal gain or advantage. 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 ora combination of the following: issuing the Respondent a written reprimand; placing the Respondent of 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 riot 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 barting the Respondent from reapplying for an educator’s. certificate fora period of time up to 10 years or permanently, EXECUTED on this |2"" day of August 2013. PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 15-004970PL