STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO, 134-3225 ASHLEY PIERRE, Respondent, / ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against ASHLEY PIERRE. 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 Conduet 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 lL. The Respondent holds Florida Educator’s Certificate 106763 7, covering the areas of English for Speakers of Other Languages (ESOL), World Language — French, Physical! Education, Reading and World Language - Spanish, which is valid through June 30, 2016, 2. At all times pertinent hereto, the Respondent was employed as a World Language Teacher at Deerfield Beach High School in the Broward County School District, MATERIAL ALLEGATIONS 3, During the 2013-2014 school year, when Respondent was alone in his classroom with 15 year old, female student, L.T., Respondent: a) hugged L.T.; b) attempted to kiss L.T. on the lips; and ASHLEY PIERRE Adminisirative Complaint Page 2 of 3 c) kissed L.T.’s arm to demonstrate how to kiss someone. 4, During the 2013-2014 school year, Respondent transported 15 year old, female * student, L.T., in his personal vehicle. Respondent gave L.T. a ride home from school on 3 oceasions, While L.T. was in Respondent’s vehicle, Respondent kissed L.'T. and touched L.T,’s inner thighs and breasts inappropriately. 5 During the 2013-2014 school year, Respondent went to the home of 15 year old, female student L.T, when L.T.’s parents were not home. L.T. allowed Respondent to enter the home, and Respondent proceeded to kiss L.T. and touch L.T.’s inner thighs and breasts inappropriately. 6. Respondent’s conduct alleged in paragraphs 3 through 5 herein, made L.T. feel uncomfortable and embarrassed, 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¢} 10), 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 mitentionally exposed a student to unnecessary embarrassment or disparagement. COUNT 5: — The allegations of misconduct set forth herein are in violation of Rule 64- 10.081(3)(¢), Florida Administrative Code, in that Respondent has harassed or discriminated against a student on the basis of tace, color, religion, sex, age, national or ethnic origin, political beliefs, marital status, handicapping condition, sexual orientation, or social and family background and shall make reasonable effort to assure that each student is protected from harassment or discrimination, ASHLEY PIERRE Administrative Complaint Page 3 of 3 COUNT 6: 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 7: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(4\(c), Florida Administrative Code, in that Respondent has used institutional privileges for personal gain or advantage. WHEREFORE, based on the reasons set forth herein and in accordance with the Explanation of Rights and Election of Rights forms attached to and made a part of this Administrative Complaint, Petitioner respectfully recommends that the Education Practices Comunission impose an appropriate sanction against the Respondent’s educator’s certificate pursuant to the authority provided in sections 1012.795¢1) and 1612.796¢7), Florida Statutes. The sanctions imposed by the Education Practices Commission may include, but are not limited to, any one or a combination of the following: issuing the Respondent a written reprimand; placing the Respondent on probation for any period of time; restricting the Respondent’s authorized scope of practice; assessing the Respondent an administrative fine; directing the Respondent to enroll in the Recovery Network Program; suspending the Respondent’s educator’s certificate for a period of time not to exceed five years; revoking the Respondent’s educator’s certificate for a period of time up to 10 years or permanently; determining the Respondent to be ineligible for certification; or barring the Respondent frorn reapplying for an educator’s certificate for a period of time up to 10 years or permanently. EXECUTED on this \)™ _ day of TUovuavu, __. 2016. J PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 16-006541PL