STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 145-1758 KREGG JOHNSON, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against KREGG 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 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 i. The Respondent holds Florida Educator’s Certificate 1190743, covering the area of Biology, which was valid through June 30, 2015. 2. At all times pertinent hereto, the Respondent was employed as a Science Teacher at Blanche Ely High School in the Broward County School District. MATERIAL ALLEGATIONS 3. During the 2013/2014 school year, Respondent inappropriately hugged and communicated with KK. and A.E., both tenth grade, female students. Respondent’s conduct included but was not limited to; placing his hands close to K.K.’s and A.E.’s buttocks while hugging them, asking KKK. to let him touch her, asking A.E. for a kiss and asking both girls to show him or send him nude pictures of themselves, KREGG JOHNSON Administrative Complaint Page 2 of 2 The Petitioner charges: STATUTE VIOLATIONS COUNT 1: 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- 10.081G)(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. 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 posed by the Education Practices Comunission 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 nat 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 cettification; or barring the Respondent from reapplying for an educator’s certificate for a period of time up to 10 years or permanently. EXECUTED onthis_(2** dayof October, 2015. PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 16-007372PL