STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 156-1541 JACKIE ALLEN, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against JACKIE ALLEN. 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 815424, covering the areas of Educational Leadership, Elementary Education, Middle Grades Integrated Curriculum, Primary Education and School Principal, which is valid through June 30, 2019. 2. At all times pertinent hereto, the Respondent was employed as a Principal at Hill- Gustat Middle School in the Highlands County School District. MATERIAL ALLEGATIONS 3. Between 2014 and 2015, Respondent created a hostile and intimidating work environment by engaging in the following conduct: a. Respondent, in the presence of staff and/or students, publically belittled the assistant principal, Respondent’s subordinate, on multiple occasions; JACKIE ALLEN Administrative Complaint Page 2 of 3 b. Respondent, made condescending remarks to R.D., a clerical worker, including, but not limited to, the following: : a. “R.D., I don’t have time to deal with you right now” or words to that effect; b. When R.D. asked Respondent a question about a scheduling issue, Respondent replied, “This is how a calendar works, you turn the page and the month changes,” or words to that effects; c. Respondent made inappropriate comments regarding the personal affairs of her subordinates; d. On certain occasions, Respondent’s rebukes and/or public admonishments would cause subordinates to cry; e. Respondent reversed school-wide decisions regarding the student body without informing staff; 4, As a result of the aforementioned incident, Respondent was removed from her position as principal. 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(1)(), 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(5)(d), Florida Administrative Code, in that Respondent has engaged in harassment or discriminatory conduct which unreasonably interfered with an individual’s performance of professional or work responsibilities or with the orderly processes of education or which created a hostile, intimidating, abusive, offensive, or oppressive environment; and further, failed to make reasonable effort to assure that each individual was protected from such harassment or discrimination. JACKIE ALLEN 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 (H™ — dayof Jui~y =, 2016. PAM STEWART, as _ Commissioner of Education State of Florida

Docket for Case No: 17-003291PL