STATE OF FLORIDA & fp ge ae EDUCATION PRACTICES COMMISSION Ln “SPY: Aup . — '% JOHN L. WINN, as é TDS PLE 4 opis ‘0 Ms 5 Commissioner of Education, HLS * Wy Of eT ye Petitioner, vs. CASE NO. 023-1452-M EULALEE PATTEN, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, John L. Winn, as Commissioner of Education, files this Administrative Complaint against EULALEE PATTEN. 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. The Respondent holds Florida Educator’s Certificate 658220, covering the areas of Educational Leadership, Elementary Education and English to Speakers of Other Languages (ESOL), which is valid through June 30, 2007. 2. Atall times pertinent hereto, the Respondent was employed as a Third Grade Teacher at Park Ridge Elementary School in the Broward County School Disirict. MATERIAL ALLEGATIONS 3. In March 2002, Respondent knowingly and unlawfully violated standardized testing procedures by providing answers to students or otherwise improperly assisting and/or coaching third-grade students during the administration of the Florida Comprehensive Assessment Test (FCAT). As a result of Respondent’s actions, the school lost its eligibility for special funding for an improved school grade, and the district found it necessary to transfer several teachers. EULALEE PATTEN Administrative Complaint Page 2 of 3 STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1008.24(1), Florida Statutes, in that Respondent knowingly and willfully violated test security rules adopted by the State Board of Education for mandatory tests administered by or through the State Board of Education or the Commissioner of Education to students, educators, or applicants for certification or administered by school districts pursuant to s. 1008.22. COUNT 2: The Respondent is in violation of Section 1008.24(1)(f), Florida Statutes, in that Respondent knowingly and willfully failed to follow test administration directions specified in test administration manuals. COUNT 3: The Respondent is in violation of Section 1008.24(1)(c), Florida Statutes, in that Respondent knowingly and willfully coached examines during testing or interfered with examinees’ responses in any way. COUNT 4: 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 5: The Respondent is in violation of Section 1012.795(1)(, Florida Statutes, in that Respondent has been found guilty of personal conduct which seriously reduces her effectiveness as an employee of the school board. COUNT 6: 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 7: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.042(c), Florida Administrative Code, in that Respondent assisted examinees in answering questions. COUNT 8: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.042(d), Florida Administrative Code, in that Respondent interfered with examinees’ answers ’ while administering test. COUNT 9: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.042(£), Florida Administrative Code, in that Respondent participated in, directed, aided, counseled, assisted in, or encouraged any activity which could result in the inaccurate measurement or reporting of the examinees’ achievement. EULALEE PATTEN Administrative Complaint Page 3 of 3 COUNT 10: 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 11: The allegations of misconduct set forth herein are in violation of Rule 6B- 1,006(5)(a), Florida Administrative Code, in that Respondent has failed to maintain honesty i in all professional dealings. 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 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 |S day of February 2006. ( JOHN L. WINN, as Commissioner of Education State of Florida

Docket for Case No: 07-003651PL