STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO, 123-0323 JULIAN RANDOLPH HARRELL, Respondent, ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against JULIAN RANDOLPH HARRELL: The’ Pétitiowér 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 846415, covering the area of Elementary Education, which is valid through June 30, 2018. 2, At all times pertinent hereto, the Respondent was employed as a Fifth Grade Teacher at Wynnebrook Elementary School in the Palm Beach County School District. MATERIAL ALLEGATIONS 3. On or about April 20, 2012, Respondent was disciplining three fifth grade, mal students when Respondent grabbed the students by the shirt or by the back of the neck and shook them. Respondent’s conduct upset the three student victims. vd 4. On or about April 23, 2012, as a result of Respondent’s conduct alleged in paragraph 3 herein, the Palm Beach County School District (District) suspended Respondent from his employment, with pay, and on or about July 16, 2012, Respondent was issued a written reprimand. JULIAN RANDOLPH HARRELL Administrative Complaint Page 2 of 3 5. On or about January 16, 2013, Respondent moved several second grade students out of the line they were waiting in for lunch by pushing, grabbing or otherwise makin g physical contact with the students. The student victims were upset by Respondent’s conduct, 6. On or about November 6, 2013, as a result of Respondent's conduct alleged in paragraph 5 herein, the District suspended Respondent from his employment, without pay, for five days. 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}@), Florida Statutes, in..that. Respondent has. violated. the. Principles... of.-Professional. Conductfor the ‘Education: ~ Profession prescribed by State Board of Education rales. 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. (SIGNATURE ON FOLLOWING PAGE) JULIAN RANDOLPH HARRELL 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 ertificate 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 44" aay of December. 2014. PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 15-006018PL