1 BEFORE THE TEACHER STANDARDS AND PRACTICES COMMISSION
'2 OF THE STATE OF OREGON
3 In the Matter of the ) STIPULATION OF FACTS,
4 Teaching License of ) ORDER OF SUSPENSION
5 RANDY SCOTT GROSS ) AND PROBATION
6 On or about January 15, 2002, the Teacher Standards and Practices Commission
7 (Commission) received a request from Stan Burczyk, Investigator for the Superintendent of
8 Public Instruction, Office of Professional Practices, State of Washington, for a copy of the
9 Commission's Licensure file for Randy Scott Gross (Gross) pursuant to an investigation
1O regarding Mr. Gross’ Washington Teaching Certificate.
11 Mr. Gross fully cooperated with the Commission's investigation. After review of the
12 matters alleged, Mr. Gross and the Commission agree that their respective interests, together
13 with the public interest, are best served by a stipulation to certain facts and the imposition of a
4 six (6) month suspension of his teaching license followed by a period of probation of four (4)
‘S years upon reinstatement of Iicensure.
16 This Order sets forth the facts upon which the parties have agreed and the sanction to
17 be imposed. Mr. Gross stipulates that there are sufficient facts contained in the Commission’s
18 files and records to support the findings of fact and conclusions of law set forth below. In
19 entering into this stipulation, Mr. Gross waives the right to a hearing to contest the finding of
20 fact, conciusion of law and order set forth below. Mr. Gross understands that the probation will
21 be subject to specific conditions.
22 This stipulation is contingent upon approval and adoption of the Order by the
23 Commission. If the Commission does not adopt this Order, neither Mr. Gross nor the
24 Commission are bound by these stipulations, and Mr. Gross retains all rights to a hearing on the
25 allegations.
26 ///
O
Page 1 STIPULATION OF FACTS, ORDER OF SUSPENSION AND PROBATION- GROSS

1 STIPULATION OF FACTS
Q 1. Mr. Gross holds a Transitional Teaching License issued August 4, 2000, valid
3 through August 4, 2003.
4 2. Mr. Gross is employed by the Jefferson County School District.
5 3. During the 1999/2000 school year Mr. Gross was employed by the Highland School
6 District, Cowiche, Washington.
7 4. On or about July 13, 2000, the Office of Professional Practices, within the Office of
8 the Superintendent of Public Instruction for the State of Washington, received a complaint letter
9 from the Superintendent of the Highland School District alleging sexual harassment and
1O inappropriate conduct by Mr. Gross.
11 5. On or about February 16, 1998, the Principal of Marcus Whitman-Cowiche
12 Elementary School, Highland School District, issued Mr. Gross a letter outlining an act of
13 professionally and socially inappropriate behavior by Mr. Gross. The letter advised Mr. Gross of
.. the potential ramifications should Mr. Gross be involved in another incident of professional
1 5 impropriety.
16 6. On or about August 9, 1999, the Superintendent of the Highland School District
17 issued a written reprimand to Mr. Gross for inappropriate physical contact with a male
18 elementary student. The written reprimand instructed Mr. Gross not to touch students except in
19 cases of emergency to protect students’ safety and that failure to comply with the directive may
20 result in termination of employment with the Highland School District.
21 7. In May 2000 the Principal of Highland High School, Highland School District, became
22 aware of allegations of unwanted touching of female high school students by Mr. Gross. The
23 District placed Mr. Gross on Administrative Leave. In a Summary of Investigation Report to the
24 Highland Superintendent, the Highland High School Principal recommended that Mr. Gross’
25 employment contract be terminated.
‘ 8. On June 14, 2000, the Superintendent of the Highland School District issued
Page 2 STIPULATION OF FACTS, ORDER OF SUSPENSION AND PROBATION- GROSS

1 Mr. Gross a letter serving as a notice of probable cause for termination of employment.
‘ 9. Mr. Gross entered into a Resignation, Settlement and Release Agreement with the
3 Highland School District. Mr. Gross submitted his unconditional and irrevocable resignation
4 from any and all contract duties effective June 15, 2000. In exchange for Mr. Gross’ resignation
5 the School District agreed to withdraw the June 14, 2000, notice of probable cause for
6 termination of employment.
7 10. On or about July 5, 2000, Mr. Gross completed an Oregon Application for Educator
8 License Form C-1. Mr. Gross answered “no” to question #3 which reads in part; “have you ever
9 failed to complete a contract for educational services in any educational or school related
10 position, or for any alleged misconduct or alleged violation of professional standards of conduct
11 been placed on leave by your employer...?"
12 11. On or about June 19, 2000, Mr. Gross completed an application for employment
3 with the Jefferson County School District in Madras, Oregon. Mr. Gross answered “no” to the
‘i questions: “have you ever been dismissed from a teaching position, have you ever been asked
15 to resign from a teaching position?“
16 lT IS SO ST7IPULATED:
17 [ZQA%M Z4 d 7/" /3 193
18 Randy cott Gross Date
19 ,_ / t
20 @aL/W'MM 1/“7'6'3
21 Victoria Ch in, Executive Director _ Date
22 Teacher St - e -' ds and Practices Commission
23 CONCLUSIONS OF LAW
24 Randy Scott Gross violated OAR 584-020-0040(4)(c) when he made a false statement
25 on his Oregon Application for Educator License Form C-1 and when he made a false statement
26 on his application for employment with Jefferson County School District. This behavior
27 constitutes Gross Neglect of Duty. The Commission's authority to impose discipline in this
Q matter is based upon ORS 342.175.
Page 3 STIPULATION OF FACTS, ORDER OF SUSPENSION AND PROBATION- GROSS

1 ORDER
Q The Commission adopts the above findings of fact and suspends the Oregon Licensure
3 of Randy Scott Gross for a period of six (6) months effective May 9, 2003. At the end of the
4 suspension period Mr. Gross may apply for reinstatement of Licensure provided he meet the
5 following conditions:
6 1. Submit a complete application pursuant to OAR 584-050-0015(3) together with
7 supporting documentation and fees;
8 2. Submit documentation that he has completed (at his own expense), an intensive
9 education program regarding appropriate boundaries with students, including sexual
10 harassment education conducted by a qualified trainer approved in advance by the
11 Commission. This intensive training shall consist of, at least eight (8) contact hours. Mr. Gross
12 shall provide the trainer with a copy of the Order. The program trainer shall provide the
3 Commission with a report of successful program completion;
‘1 3. Submit a written consent form to the Commission granting permission for
15 the Commission’s Executive Director to contact the provider of the counseling; and
16 4. Submit a report to the Commission, by a qualified provider of counseling services
17 described above, verifying Mr. Gross‘ suitability to resume teaching as a licensed educator.
18 Upon reinstatement of his teaching license, Mr. Gross shall be placed on probation for a
19 period of four (4) years subject to the conditions that:
20 1. Mr. Gross shall comply with all Standards for Competent and Ethical Performance of
21 Oregon Educators pursuant to Oregon Administrative Rules, Chapter 584, Division 020; and
22 2. Mr. Gross shall provide an annual report from his building supervisor to the Executive
23 Director of the Commission verifying that Mr. Gross has not violated any Standards. Said report
24 will be due on or before March 15"1 of each year beginning the academic year of reinstatement
25 of licensure.
‘5 // l
Page 4 STIPULATION OF FACTS, ORDER OF SUSPENSION AND PROBATION- GROSS

i ,u
1 lT IS SO ORDERED this clay of May 2003.
Q TEACHER STANDARDS AND PRACTICES COMMISSION
3 \_.
4 By M
5 rc oria Chambe in, Executive Director
6 Approved as to form:
7 éK/T
8 / '
9 enryJ. apl n, OS #83055 [040203]
10 Attorney for Randy Scott Gross
Page 5 STIPULATION OF FACTS, ORDER OF SUSPENSION AND PROBATION- GROSS