Former Cedar Rapids Washington coach Tony Lombardi has been formally charged with four counts of violating rules that govern the ethical conduct of teachers.

The Iowa Board of Educational Examiners has found "probable cause" of a violation of Board rules and has scheduled a hearing for Sept. 23-24 in Des Moines before Administrative Law Judge John Priester, who will be acting on behalf of the BoEE.

Lombardi could have his teaching license revoked, depending on how the case is resolved.

Lombardi has resigned as the football coach and baseball coach at Washington High School but has a contract to teach in the Cedar Rapids Community School district for the 2013-14 school year, pending a formal building assignment.

Duane T. Magee, the Executive Director of the Iowa BoEE, sent Lombardi a "Notice Of Hearing And Statement of Charges" in a letter dated Aug. 1. Kathi Jensen, one of the Washington parents who is involved in the case, received a copy of the letter and shared the document with the Metro Sports Report Tuesday morning.

Lombardi has been charged with these four counts:

1. Respondent is charged with unethical practice by failing to make reasonable efforts to protect the health and safety of students or creating conditions harmful to student learning.

2. Respondent is charged with unethical practice by conducting professional business in such a way that the practitioner repeatedly exposes students or other practitioners to unnecessary embarrassment or disparagement.

3. Respondent is charged with unethical practice by engaging in any act of illegal discrimination, or otherwise denying a student participation in the benefits of any program on the grounds of race, color, religion, age, sex, sexual orientation, gender identity, disability, marital status or national origin.

4. Respondent is charged with unethical practice by intentionally disclosing confidential information including, but not limited to, unauthorized sharing of information, assessment or testing results, or family income.

The Board of Educational Examiners received a complaint against Lombardi on June 14, 2012 and began its investigation on June 21, 2012. Lombardi has consistently denied comment on the case and did not respond to an e-mail from the Metro Sports Report as of noon Tuesday.

The Iowa Board of Educational Examiners listed "factual circumstances" in its letter to Lombardi, including the following:

• The investigation revealed that Respondent used language with student-athletes that was profane, demeaning, and/or inappropriate on multiple occasions.
• Respondent used language with student-athletes and practitioners that constitute racial, religious and/or ethnic slurs.
• Respondent's pattern of bullying behavior and language with students created a hostile environment.
• Respondent disclosed confidential student academic information at the football banquet.

Lombardi was given 20 days to file an answer to the charges. He is required to specifically admit, deny or otherwise respond to the allegations.

Lombardi can request an adjustment of the hearing date and time. At the hearing, he may appear personally or be represented by an attorney, at Lombardi's expense. Lombardi will be allowed an opportunity to respond to the charges at the hearing.

Each party will be allowed to testify, examine and cross-examine witnesses and present documentary evidence.

The office of the Iowa Attorney General is responsible for prosecuting and representing the public interest (the State) in this proceeding, according to the BoEE document.

Duane T. Magee, the Executive Director of the Iowa Board of Educational Examiners, signed the letter that was sent to Lombardi.

The letter states that "this matter may be resolved by surrender of your license or an agreement to accept a lesser sanction."

The hearing is scheduled to begin on Monday, Sept. 23 at 9 a.m. in the Department of Inspections and Appeals, Wallace State Office Building, Third Floor, 502 E. 9th Street, Des Moines.

Lombardi began working for Cedar Rapids Schools on Aug. 1, 2006.