“People need to stand up and demand that the people in charge do the right thing."

A formal complaint filed with the Okaloosa County School Board alleges Superintendent Mary Beth Jackson has committed nearly 20 violations of state law and/or Florida Department of Education policies.

The complaint, turned in by Fort Walton Beach resident Gene Earley, also claims two school district employees who report directly to Jackson — Stacie Smith and Henry Kelley — have committed serious breaches of existing statutes and policies.

Earley suggests the board consider forwarding his complaint to the Florida Ethics Commission, the state DOE, attorney general and/or governor. Three current or former Okaloosa County School District employees have been arrested since the school year began and the First Judicial Circuit State Attorney’s Office continues to actively investigate the district.

“People need to stand up and demand that the people in charge do the right thing,” Earley told the Daily News.

School Board Chairman Lamar White said since receiving the Earley document he had researched how other school districts in Florida have handled formal complaints against superintendents.

“I am not convinced it is within the School Board’s prerogative to adjudicate that matter,” he said of the complaint against Jackson. “I believe it would more appropriately fall into the realm of the governor of the state and/or the Department of Education and the Commissioner of Education, Pam Stewart.”

The School Board could call upon its attorney, Jeff McInnis, to secure the services of an outside investigator to conduct an independent investigation and present those findings to the state, White said. A board vote in favor of such a measure would be required for that request to be made. The board next meets on Dec. 11.

Earley states “the heart” of his complaint involves the school district allowing three of its employees — Marlynn Stillions, Roy Frazier and Stephen Hall — to continue working despite investigative confirmation that all three had seriously violated school district policies.

Stillions and Frazier were both found to have physically mistreated special needs children in their care. Frazier was suspended for three days in the spring of 2016 and allowed to continue teaching for the district until his retirement this past June, which occurred just weeks before the state permanently revoked his teaching certificate. Stillions had been moved from one school to another prior to her arrest Sept. 13 on child abuse charges.

Hall was sent to at least three different schools in Okaloosa County, and at each complaints of sexual harassment were lodged against him. Hall remains employed as a school district custodian, though he’s been placed on administrative leave.

“Stacie Smith and the Superintendent, Mary Beth Jackson, conducted OCSD/HR investigations; confirmed complaints; and then released (the three) back on the students, teachers, administrators, parents and volunteers of the OCSD,” Earley’s complaint said. “It is a fact that these two individuals did this. This is not disputed. This is not conjecture. But the how and why is.”

Contacted via email, Jackson said she had not seen Earley’s complaint, which was sent to the five county School Board members and McInnis.

Kelley, the school district’s spokesman, did not return a phone call seeking comment or respond to an email.

The complaint states Jackson failed to conduct a proper inquiry into allegations that Smith, the assistant superintendent of human resources, had declined to provide public records associated with the handling of a 2016 school district investigation of Stillions, then a pre-K teacher at Kenwood Elementary School.

A report filed following the Stillions investigation, which confirmed the teacher had improper interactions/procedures with a child or children in her care, was set aside, on Smith’s order, without being acted upon by the district. She said Arden Farley, the district investigator who compiled the report, had failed to follow guidelines within the teacher’s union Master Contract.

A year later an inquiry initiated when the same report was turned over to the Okaloosa County Sheriff’s Office resulted in Stillions being arrested on four felony counts of child abuse without great bodily harm.

Earley claims documents provided by the Okaloosa County teacher’s union on Stillions’ behalf — a “challenge” of investigation findings Smith claimed in a memo to have thoroughly reviewed — have never been made public.

“Mary Beth Jackson has completely mismanaged and failed to investigate my formal complaint against Ms. Stacie Smith,” Earley’s complaint said. “By failing to support the public’s inquiry into OCSD records and documents; and, by not conducting adequate investigations on her personal staff, Ms. Jackson continues to put students at risk.”

Earley’s complaint also alleges that in not only the case of Stillions, but Frazier and Hall as well, Jackson had knowledge of abuses and failed to act.

“By failing to properly ensure that Stillions, Frazier and Hall were investigated by the proper state authorities and removed from the OCSD system, Ms. Jackson in fact became complicit and accomplice under [Florida Statute] to every abusive act committed after Ms. Jackson administratively buried these confirmed investigative reports,” the complaint said.

The complaint also alleges that Jackson “failed to ensure the formal complaint against Ms. Stacie Smith and the preliminary investigation” were kept confidential, as he contends is required by state statute.

Earley contends he turned his complaint against Smith over to Jackson, only to have her spokesman, Kelley, pass it and some emails to a television news reporter.