STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, VS. CASE NO, 145-1233 STEPBEN JACKSON, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against STEPHEN JACKSON. 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 Certificaté“1221007, covering the area of Chemistry, which is valid through June 30, 2016. 2 At ali times pertinent hereto, the Respondent was employed as a Science Teacher at Lyman High School in the Seminole County School District, MATERIAL ALLEGATIONS 3, In or around March 2014 through May 2014, Respondent engaged in a sexual relationship with J.S., a male, nineteen year old, who was also a student at the schoo! where Respondent taught. Respondent knew that J.S. was a student at the school where Respondent was employed as a Chemistry teacher. Furthermore, Respondent contacted J.S. via electronic communication during school hours. 4, Furthermore, during the course of Seminole County School District’s investigation of the aforementioned incident, Respondent stated that he discontinued contact with STEPHEN JACKSON Administrative Complaint Page 2 of 3 JS. until J.S. graduated from high school. However, during the course of the same investigation, Respondent stated that he engaged in frequent intimate-type communications and physical encounters with J.S. from March 2014 through May 2014. Respondent’s earlier statement is in direct conflict with the latter admission; therefore, Respondent lied in an educational matter. 5. On or about August 28, 2014, Respondent resigned in lieu of termination. The Petitioner charges: STATUTE VIOLATIONS COUNT i: 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 2: 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 3: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(3\(h), Florida Administrative Code, in that Respondent has exploited a relationship with a student for personal gain or advantage. COUNT 4: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(5}fa), Florida Administrative Code, in that Respondent has failed to maintain honesty in all professional dealings. (SIGNATURE ON FOLLOWING PAGE) STEPHEN JACKSON 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 periad of time up to !0 years or permanently. EXECUTED on this {Qt day of Eatow oe 2016. é PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 16-004430PL