STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 134-2723 EUNICE LUCILLE JOHNSON, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against EUNICE LUCILLE JOHNSON. 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 io Rule 6A-10.081, Florida Administrative Code, Principles of Professional Conduct for the Education Profession in Florida, said sancions 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 537463, covering the ‘areas of Elementary Education, English for Speakers of Other Languages (ESOL), Reading and Varying Exceptionalities, which is valid through June 30, 2020. 2, At all times pertinent hereto, the Respondent was employed as a Sixth Grade Teacher at Lake Trafford Elementary School in the Collier County School District. MATERIAL ALLEGATIONS 4 3. During the 2013/2014 school year, Respondent inappropriately disciplined students. Examples of Respondent’s inappropriate discipline include but are not limited to: a) Respondent required D.S. and J.V., two male, sixth grade students, to write apology letters to the assistant principal for what Respondent perceived as an incorrect statement one of the students had made to the assistant principal. Respondent required D.S, and J.V. to work on the apologies for approximately EUNICE LUCILLE JOHNSON Administrative Complaint Page 2 of 3 one week, during class time. Respondent excluded D.S. and IV, from class lessons during the time they were required to write the letters and gave them zeros as grades for the missed work. b) Respondent did not allow students to keep checked-out library books in their desks over-night. When several students left books in their desks, Respondent confiscated the books without informing the students or returning them upon’ request, leaving the students financially responsible for the books. c) Respondent secluded, in an unsupervised area, multiple students from class on a regular basis, denying them participation in class lessons. 4, During the 2013/2014 school year, Respondent failed to properly utilize class time and resources to the best advantage of her students. Respondent’s conduct included but was not limited to: d) During benchmark testing, Respondent failed to properly monitor students and instead spent the time on her computer, contrary to school instructions and Respondent’s signed agreement. e) Respondent refused to directly address student questions and instead required that they seek the answer from others prior to asking questions of Respondent. f) Respondent spent class time on her computer without interacting with students. g) Respondent assigned student grades that were not supported by the work done * by the students. The Petitioner charges: STATUTE VIOLATIONS COUNT i: 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 Sect ion 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 EUNICE LUCILLE JOHNSON Administrative Complaint Page 3-of 3 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- 10.081G)¢), Florida Administrative Code, in that Respondent has intentionally exposed a student to unnecessary embarrassment or disparagement. 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 9% day of September. 2015. GA. a aoe PAM STEWART. as Commissioner of Education State of Florida

Docket for Case No: 16-007370PL