STATE OF FLORIDA EDUCATION PRACTICES COMMISSION RICHARD CORCORAN, as Commissioner of Education, Petitioner, vs. CASE NO. 189-0112 LINCOLN M. LOUCKS, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Richard Corcoran, as Commissioner of Education, files this Administrative Complaint against LINCOLN M. LOUCKS. 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 577517, covering the areas of Exceptional Student Education (ESE), Middle Grades and Social Science, which is valid through June 30, 2021. 2. At all times pertinent hereto, the Respondent was employed as a Social Studies Teacher at Leesburg High School in the Lake County School District. MATERIAL ALLEGATIONS 3. Respondent has a history of discipline for making 7 students feel uncomfortable by hugging them. On or about March 10, 2017, he received a reprimand for such behavior. On_or about May 15, 2018 and May 16, 2018, Respondent inappropriately 4. touched I a Mlbycar-old MEM student, by rubbing [MM knee, back, and inner thighs. Respondent also tapped ma: buttocks with an open palm. AC-2 LINCOLN M. LOUCKS Administrative Complaint Page 2 of 3 5. On or about May 15, 2018, Respondent engaged in inappropriate dialogue with | when he asked the student if | was having sex with | discussed sexual positions, and asked how easily was sexually aroused. 6. Respondent’s conduct caused to feel uncomfortable. 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)(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 3: 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 4: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(2)(a)5, Florida Administrative Code, in that Respondent has intentionally exposed a student to unnecessary embarrassment or disparagement. (SIGNATURE ON FOLLOWING PAGE) AC-3 LINCOLN M. LOUCKS 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 Sf day of September 2019. Y Y Nh. thle ——— RICHARD CORCORAN, as Commissioner of Education State of Florida AC-4 FROM: Florida Department of Education Office of the General Counsel TO: DOAH Clerk of Court RE: UNREDACTED DOCUMENT The General Counsel’s Office reviewed and redacted certain confidential verbiage within the document(s) included prior to transferring the case to DOAH. For the convenience of the Court, this is an unredacted version of those documents. FLORIDA DEPARTMENT OF EDUCATIO State Board of Education ———__________—_ fldoe.org Richard Corcoran Commissioner of Education Andy Tuck, Chair Marva Johnson, Vice Chair Members Ben Gibson Tom Grady Michael Olenick Ryan Petty Joe York February 24, 2020 Mr. John Maclver, Director and Chief Judge Division of Administrative Hearings The DeSoto Building 1230 Apalachee Parkway Tallahassee, Florida 32399-1550 Re: Richard Corcoran, as Commissioner of Education v. Lincoln Mark Loucks, Case Number: 189-0112 Dear Judge Maclver: As there appear to be material facts in dispute in the above-referenced case, I am forwarding this matter to your office for a full evidentiary hearing pursuant to Section 1012.796(6), Florida Statutes. Ron Weaver will represent the Department in this matter. Please call me if you have any questions. My telephone number is (850) 245-0443. Sincerely, /s/ Anastasios Kamoutsas Anastasios Kamoutsas, Assistant General Counsel Office of the General Counsel cc: Ron Weaver, Esquire The Office of Professional Practices Services CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing was provided by electronic mail to Respondent, Lincoln Loucks, at lincmark@yahoo.com, this 24th day of February, 2020. /s/ Anastasios Kamoutsas Anastasios Kamoutsas, Esquire Office of the General Counsel www.fidoe.org 325 W. Gaines Street — Suite 1544 | Tallahassee, FL 32399-0400 | 850-245-0443 ELECTION OF RIGHTS Richard Corcoran, Commissioner of Education, Petitioner, vs. File No.: 189-0112 LINCOLN MARK LOUCKS Respondent. / Mark your election by checking option 1, 2, 3 or 4. (Select ong option) 1. |[ ] FORMAL HEARING OPTION | dispute the 2; IA SETTLEMENT OPTION [I neither admit nor deny the allegations of the Administrative Complaint and I request a allegations and request a forty-five (45) day period to negotiate a Formal Hearing before a Hearing Officer of the Division of settlement agreement. If an agreement is not reached I request: Administrative Hearings. The facts I dispute are: (Select One) a [| ]Informal Hearing - | do not dispute the allegation Or [ Formal Hearing - The facts I dispute are: oe Yi Pkep Rly pt F? U Chir Attach additional sheet(s) if needed. LAA, Conwy, *If neither Informal nor Formal is checked, the action will be scheduled for an Informal Hearing. uw [| ] INFORMAL HEARING OPTION I do not dispute the allegations of the Administrative Complaint and request an Informal Hearing before the Education Practices 4. |[ ] SURRENDER OPTION I voluntarily surrender my Commission. certificate(s) for permanent revocation. I have read the Explanation of Rights and understand my options. (EXECUTIO: FORE ANOTARY PUBLIC NOT REQUIRED IF CHOOSING OPTION 1) Signature of Respondent STATE OF FLORIDA uf, C. COUNTYOF La Ve; / 27°07 Blue la, ER ow a The foregoing instrument was acknowledged before me this Street Address Be dayof Octo be :2015_, 349 on (eleen a i EL b (Zz Lanccla Hark Ces cKS G27) 417-4127 : ) Print Respondent's Name) Telephoiieé No. JiNemARK © YA) 00. Cour EMail Address [ ] Check if ok to correspond via email Personally Known __ or Produced Identification Type of c ( ‘ OL 3 ata Carmen Espinoza = My Commission GG 266398 Expires 10/1 4/2022 Print, Type or Stamp Commissioned Name of Notary Public Caz mon C 5p tqaZe Your fully executed election of rights form must be returned within 21 days to: PROFESSIONAL PRACTICES SERVICES 325 WEST GAINES STREET, SUITE 224 TALLAHASSEE, FLORIDA 32399-0400 or via email to EOR@fldoe.org EOR-1 State Board of Education Andy Tuck, Choir Marva Johnson, Vice Chelr Members Ben Gibson Tom Grady Michael Olenick Joe York September 5, 2019 Mr. Lincoln Loucks 12909 Blue Heron Court Clermont, Florida 34711 Dear Mr. Loucks: FLORIDA DEPARTMENT OF EDUCATION fidoc.ong Richard Corcoran Commissioner of Education CERTIFIED MAIL RE: Finding of Probable Cause Case No.: 189-0112 DOE No.: 577517 Pursuant to the provisions of Sections 1012.795 and 1012.796, Florida Statutes, I find probable cause exists to justify sanctions against your Florida educator certificate. Penalties levied against you may include reprimand, fine, probation, restriction of the scope of practice, suspension not to exceed five years, revocation not to exceed ten years or the permanent revocation of your Educator Certificate. An Administrative Complaint and Election of Rights (appeal) form are enclosed. Please complete and sign the enclosed Election of Rights form and return the fully executed form to the Office of Professional Practices Services, 325 West Gaines Street, 224E, Tallahassee, FL 32399-0400. Should you have any questions regarding this matter, contact the Office of Professional Practices Services at (850) 245-0438. Please govern yourself accordingly. Sincerely, Vp Richard Corcoran ENCLOSURES www.fidoe.org 325 W. Gaines Street | Tallahassee, FL32399-0400 | 850-245-0505 AC-1 STATE OF FLORIDA EDUCATION PRACTICES COMMISSION RICHARD CORCORAN, as Commissioner of Education, Petitioner, vs. CASE NO. 189-0112 LINCOLN M. LOUCKS, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Richard Corcoran, as Commissioner of Education, files this Administrative Complaint against LINCOLN M. LOUCKS. 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 577517, covering the areas of Exceptional Student Education (ESE), Middle Grades and Social Science, which is valid through June 30, 2021. 2. At all times pertinent hereto, the Respondent was employed as a Social Studies Teacher at Leesburg High School in the Lake County School District. MATERIAL ALLEGATIONS 3. Respondent has a history of discipline for making female students feel uncomfortable by hugging them. On or about March 10, 2017, he received a reprimand for such behavior. 4. On or about May 15, 2018 and May 16, 2018, Respondent inappropriately touched A.Y., a 17-year-old female student, by rubbing her knee, back, and inner thighs. Respondent also tapped A.Y.’s buttocks with an open palm. AC-2 LINCOLN M. LOUCKS Administrative Complaint Page 2 of 3 5. On or about May 15, 2018, Respondent engaged in inappropriate dialogue with A.Y., when he asked the student if she was having sex with her boyfriend, discussed sexual positions, and asked how easily she was sexually aroused. 6. Respondent’s conduct caused A.Y. to feel uncomfortable. 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)(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 3: 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 4: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(2)(a)5, Florida Administrative Code, in that Respondent has intentionally exposed a student to unnecessary embarrassment or disparagement. (SIGNATURE ON FOLLOWING PAGE) AC-3 LINCOLN M. LOUCKS 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 Sf day of September 2019. Y Y Nh. thle ——— RICHARD CORCORAN, as Commissioner of Education State of Florida AC-4

Docket for Case No: 20-000997PL