STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 156-0334 JASON A. MEMMER, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against JASON A, MEMMER. 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 1087981, covering the area of Social Science, which is valid through June 30, 2019, 2. At all times pertinent hereto, the Respondent was employed as a Social Science Teacher at John Hopkins Middle School in the Pinellas County Schoo! District. MATERIAL ALLEGATIONS 3. In or around July of 2014, Respondent applied for and received a grant through the Teach for Excellence program with the Pinellas Education Foundation. The grant was awarded for purposes of purchasing three computers and three Microsoft Office subscriptions for use in Respondent’s classroom at Johns Hopkins Middle School. After receiving the computers, Respondent was scheduled to be transferred to another school, Bay Pointe Middle School, also in Pinellas County, Florida. Upon being notified that the computers he obtained with the grant proceeds would stay at John Hopkins Middle School instead of being transferred with Respondent to Bay Pointe Middle School, Respondent submitted a fraudulent letter to the JASON A. MEMMER Administrative Complaint Page 2 of 3 principal of John Hopkins Middle School. The fraudulent letter was purportedly from the treasurer of the Pineilas Education Foundation and authorized Respondent to take the subject computers to Bay Pointe Middle School for use in his new classroom. 4, As a result of Respondent’s conduct alleged in paragraph 3 herein, the Pinellas County School District moved to terminate Respondent’s employment, and on or about August 4, 2015, Respondent resigned his employment in lieu of termination. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of section 1012.795(1)(d), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude as defined by rule of the State Board of Education. COUNT 2: 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 3: The Respondent is in violation of section 1012.795(1)(j), 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 4: 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. COUNTS: 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. (SIGNATURE. ON FOLLOWING PAGE) JASON A. MEMMER 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 period of time up to 10 years or permanently. EXECUTED on this \@™ day of WiavCin , 2016. PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 16-007371PL