STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 167-2544 RALPH LAWRENCE VAUGHN, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against RALPH LAWRENCE VAUGHN. 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 739816, covering the areas of Economics and Business Education, which is valid through June 30, 2020. 2. At all times pertinent hereto, the Respondent was employed as a Business Education Teacher at Vero Beach High School in the Indian River County School District. MATERIAL ALLEGATIONS 3. During the 2015/2016 school year, Respondent taught high school business classes and in that capacity, administered industry certification exams (ICE) which qualified students as having knowledge and understanding of certain programs. In the process of becoming authorized to access and administer ICE, Respondent electronically agreed to a non- disclosure statement whereby Respondent acknowledged that the content of the exams was confidential and agreed not to disclose it or share it for any purpose not expressly approved by - the exam owners, RALPH LAWRENCE VAUGHN Administrative Complaint Page 2 of 3 4. Respondent violated the terms of the agreement and jeopardized the integrity of. the tests when he personally took certain exams multiple times for the purpose of sharing the content with his students. Respondent did share the exam content with students prior to students taking the ICE and as a result, certifications and credits awarded to students for passed exams were revoked. 5. Respondent improperly benefited when his students passed ICE as a result of Respondent providing them with exam content prior to the tests in the following ways: a) Respondent’s students’ test scores qualified Respondent to receive funds above and beyond his salary in the amount of $25 to $100 per test passed. b) Student scores also had an impact on Respondent's yearly evaluation making him eligible for pay raises. c) Finally, higher passage rates on the ICE improved the grade of the school as a whole, potentially making Respondent eligible for an additional bonus, The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of section 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. RULE VIOLATIONS COUNT 2: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(2)(a)1, 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 3: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(2)(b)3, Florida Administrative Code, in that Respondent has used institutional privileges for personal gain or advantage. COUNT 4: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(2)(c)1, Florida Administrative Code, in that Respondent has failed to maintain honesty in all professional dealings. (SIGNATURE ON FOLLOWING PAGE) RALPH LAWRENCE VAUGHN 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 Was day of abr Jac ; > 2018. PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 18-003267PL