STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, VS. CASE NO. 134-2100 GREGORY STUART MOORE, Respondent. ADMINISTRATIVE COMPLAINT etitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against’ GREGORY STUART MOORE. 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 887903, covering the area of English, which is valid through June 30, 2017. 2. At all times pertinent hereto, the Respondent was employed as a Technology Education Teacher at Hollywood Hills High School in the Broward County School District. MATERIAL ALLEGATIONS 3, On or about November 3, 2011, Respondent entered into a Last Chance Agreement with the Broward County School Board, wherein Respondent agreed to be subjected to random drug and alcohol tests. Respondent further agreed that “any further disciplinary action or arrests relating to drugs and or alcohol use will result in termination” from his employment with the district. 4, On or about December 9, 2013, while on duty and responsible for students, Respondent submitted to an alcoho! and drug test and tested positive for alcohol. GREGORY STUART MOORE Administrative Complaint Page 2 of 3 5. On or about January 23, 2014, as a result of the positive test result for alcohol alleged in Paragraph 4 of this Administrative Complaint, the Broward County School District terminated Respondent’s 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)q), 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. (SIGNATURE ON FOLLOWING PAGE) GREGORY STUART MOORE 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 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 _G __ day of _Pangh, , 2015, Ld Lecce, PAM STEWART, as = Commissioner of Education State of Florida

Docket for Case No: 15-006017PL