STATE OF FLORIDA EDUCATION PRACTICES COMMISSION CEAPR IS Ayio:3 3 : JOHN L. WINN, as - & as Commissioner of Education, 39, A -— eee et ee “i See vw Petitioner, BAO, ; Bape yo % eee, Ye vs. CASE NO. 045913 84-8 = , w am — PAMELA YVONNE WILLIAMS, : Respondent. Ol-i5 bS pl / ADMINISTRATIVE COMPLAINT Petitioner, John L. Winn, as Commissioner of Education, files this Administrative Complaint against PAMELA YVONNE WILLIAMS. 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-1.006, 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. Elementary ] The Respondent holds Florida Educator’s Certificate 626176, covering the areas of Education, Emotionally Handicapped and English To Speakers Of Other Languages (ESOL) , which is valid through June 30, 2010. 2 Atall times pertinent hereto, the Respondent was employed asa Teacher at Highland Oaks Middle School in the Miami-Dade County School District. MATERIAL ALLEGATIONS 3. On or about May 5, 2004, the Respondent utilized inappropriate physical force with aminor female student in that she grabbed the student's arm and forced it behind the student's back. In doing so, the Respondent broke the girl's arm. PAMELA YVONNE WILLIAMS Administrative Complaint Page 2 of 3 STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1)(c), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude. COUNT 2: The Respondent is 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 3: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(a), 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 6B- 1.006(3)(e), Florida Administrative Code, in that Respondent has intentionally exposed a student to unnecessary embarrassment or disparagement. 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 PAMELA YVONNE WILLIAMS ~ 21o AMINE Administrative Complaint De APR YS ENO: 33 Page 3 of 3 nee exceed five years; revoking the Respondent’s educator’s certificate for a period of time up to 10 years or permanently; 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 J+ dayof Tebroaru _, 2006. (ey lil tthe JOHN L. WINN, as Commissioner of Education State of Florida

Docket for Case No: 06-001565PL