STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 123-1920 LINDA BARBARA KALTER, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner’ of Education, files this Administrative Complaint against LINDA BARBARA KALTER. 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 1, The Respondent holds Florida Educator's Certificate 574746, covering the areas of Mathematics and Exceptional Student Education, which is valid-through June 30; 2017: 2. At all times pertinent hereto, the Respondent was employed as a Mathematics Teacher at Wolf Lake Middle School in the Orange County School District. MATERIAL ALLEGATIONS 3. On or about October 16, 2012, Respondent acted inappropriately when she forcefully pulled a lollipop from the mouth of K.S., a twelve-year-old, female student, damaging the student’s dental work. 4. During the 2012/2013 school year, Respondent inappropriately disciplined students by yelling, snatching items from students’ hands, slamming books and hitting students. LINDA BARBARA KALTER Administrative Complaint Page 2 of 3 5. On or about August 13, 2013, the District suspended Respondent for a period of four days as a result of her conduct. The Petitioner charges: STATUTE VIOLATIONS COUNT L: 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. (SIGNATURE ON FOLLOWING PAGE) LINDA BARBARA KALTER 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; 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 {5 day of Apri | , 2015, PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 16-000592PL