STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 145-1986 CHRISTINE JANE KIRCHNER, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against CHRISTINE JANE KIRCHNER. 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 lL The Respondent holds Florida Educator’s Certificate 534068, covering the area of English, which is valid through June 30, 2019. 2. At all times pertinent hereto, the Respondent was employed as an English Teacher at Coral Reef Senior High School in the Miami-Dade County School District. MATERIAL ALLEGATIONS 3. During the 2014-2015 school year, Respondent made several racially and sexually inappropriate comments to her students on school grounds and during school hours. These comments include, but are not limited to, the following: (a) In or around November 2014, Respondent called G.C., a student in her classroom, an “asshole” and “jackass” or words to that effect; CHRISTINE JANE KIRCHNER Administrative Complaint Page 2 of 3 (b) In or around November 2014, Respondent referred to G.C.’s work, as “shit” or words -to that effect; (c) In or around November 2014, Respondent called N.D., a student in her classroom, a “jackass” or words to that effect; (d) In or around November 2014, Respondent told C.G., an African-American student in her class, to not steal from her classroom because he would be blamed for said theft on the basis of his race; (e) In or around November 2014, Respondent inappropriately discussed the similarities and differences between the female nipple and clitoris with a female student in her class; and (f) In or around November 2014, Respondent referred to students as “retarded” or “retards” or words to that effect. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: 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 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. (SIGNATURE ON FOLLOWING PAGE) CHRISTINE JANE KIRCHNER 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 \6™ day of _Yaycin 2016. PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 17-001897PL