STATE OF FLORIDA EDUCATION PRACTICES COMMISSION JOHN L. WINN, as Commissioner of Education, Petitioner, vs. Case Number: 034-2551-M PATRICIA KINSLAND ALLEN, Respondent. O lo _ | a a lo p eo / ADMINISTRATIVE COMPLAINT Petitioner, John L. Winn, as Commissioner of Education, files this Administrative Complaint against PATRICIA KINSLAND ALLEN. The Petitioner seeks the appropriate disciplinary sanction of the Respondent's educator's certificate pursuant to Sections 1012.795 and 1012.796, Florida Statutes, and pursuant to Rule 6B-1006, 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 386484, covering the areas of Elementary Education, English to Speakers of Other Languages and Social Science which is valid through June 30, 2008. 2. At all times pertinent hereto, the Respondent was employed as a Social Studies Teacher at Ramblewood Middle School in the Broward County School District. MATERIAL ALLEGATIONS 3. On or about December 2, 2003, the Respondent reported to work and was at her school site while under the influence of alcohol. The Respondent subsequently admitted that she consumed alcohol that morning before reporting for work. 4. On or about February 6, 2004, the Respondent reported to the office of the PATRICIA KINSLAND ALLEN Administrative Complaint Page 2 of 2 Broward County School District’s special investigative unit to give a compelled statement in reference to the December 2, 2003 incident. At that time the Respondent was also under the influence of alcohol she consumed earlier that morning. 5. Respondent submitted to breathalyzer tests on both December 2, 2003 and February 6, 2004. The results of each breathalyzer test disclosed that the Respondent was legally intoxicated on both dates. STATUTE VIOLATIONS COUNT 1. The allegations of misconduct set forth herein are in violation of Section 1012.795(1)(i), 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 6B-1.006(3)(a), Florida Administrative Code, in that the Respondent failed to make reasonable effort to protect the student from conditions harmful to learning and/or to the student’s mental and/or physical health and/or safety. WHEREFORE, the Petitioner recommends that the Education Practices Commission impose an appropriate penalty pursuant to the authority provided in Sections 1012.795(1) and 1012.796(7), Florida Statutes, which penalty may include a reprimand, probation, restriction of the authorized scope of practice, administrative fine, suspension of the teaching certificate not to exceed three years, permanent revocation of the teaching certificate, or combination thereof, for the reasons set forth herein, and in accordance with the Explanation and Election of Rights forms which are attached hereto and made a part hereof by reference. EXECUTED on this__|_ day of Aval 4 2005. Sto John L. Winn, as Commissioner of Education, State of Florida

Docket for Case No: 06-001236PL