STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs, CASE NO. 123-2574 . ELITAH MARK RICHARDSOR, Respondent, ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against ELIJAH MARK RICHARDSON. 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 696450, covering the areas of Elementary Education and English for Speakers of Other Languages (ESOL), which is valid through June 30, 2019. 2. At all times pertinent hereto, the Respondent was employed as a Fourth and Fifth Grade Reading Teacher at West Hollywood Elementary School in the Broward County School District. MATERIAL ALLEGATIONS 3. During the 2012-2013 school year, Respondent engaged in inappropriate conduct when he: (a) disciplined his fifth grade students on multiple occasions by grabbing students by the shoulders and shaking them; ELUAH MARK RICHARDSON Administrative Complaint Page 2 of 3 (b) disciplined his fifth grade students on multiple occasions by putting his face near the face of a student and using a loud tone or yelling at the student; (c) used profanity during class, including saying the words “shit” and “fuck”; and (d) threw a book at fifth grade, female student N.M., causing the book to strike N.M. 4, On or about April 5, 2013, Respondent received notice that the Office of Professional Practices Services of the Florida Department of Education had opened a case for purposes of investigating Respondent’s alleged inappropriate conduct, and if founded, the allegations could lead to disciplinary action against Respondent’s Florida Educator’s Certificate, On or about April 26, 2013, Respondent submitted an Application for the renewal of his Florida Educator's Certificate to the Florida Department of Education. In his sworn responses to the Application, Respondent falsely answered “No” to the question: “Do you have any current investigative action pending in this state or any other state against a professional license or certificate or against an application for a professional license or certificate?” The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1 (a), Florida Statutes, in that Respondent obtained or attempted to obtain a teaching certificate by fraudulent means. 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)(€), 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(5)(a), Florida Administrative Code, in that Respondent has failed to maintain honesty in all professional dealings. ELIJAH MARK RICHARDSON Administrative Complaint Page 3 of 3 COUNT 6: The Respondent is in violation of Rule 6A-10.081(5)(h), Florida Administrative Code, in that Respondent has submitted fraudulent information on a document in connection with professional activities. 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_[O** _ day of April 2015, bb feeers PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 16-000942PL