STATE OF FLORIDA EDUCATION PRACTICES COMMISSION DR. ERIC J. SMITH, as Commissioner of Education, Petitioner, vs. CASE NO. 056-2618-W LINDA ASHLEY, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Dr. Eric J. Smith, as Commissioner of Education, files this Administrative Complaint against LINDA ASHLEY. The Petitioner secks the appropriate disciplinary sanction of the Respondent’s educator’s certificate pursuant to Sections 1012.315, 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 329981, covering the areas of English and Reading, which is valid through June 30, 2013. 2. At all times pertinent hereto, the Respondent was employed as an English Teacher at Barbara Goleman Senior High School in the Miami-Dade County School District. MATERIAL ALLEGATIONS 3, During February 2003, Respondent became aware that she was 6 college credits or 120 in-service credits short of renewal requirements for her educator’s certificate which was due to expire in June 2003. 4. Upon Respondent’s request, Respondent’s husband referred her to the Move On Toward Education and Training (MOTET) program. Respondent registered with the program and paid over $1600 for tuition. Filed January 13, 2011 11:23 AM Division of Administrative Hearings LINDA ASHLEY Administrative Complaint Page 2 of 3 5. Respondent attended no more than 4 classes. Respondent had no textbooks, no syllabi, no tests or assignments. 6. Respondent assumed she would receive 3 college credits when she signed up with the MOTET program in February 2003 but when Respondent received a transcript in March 2003, it reflected 6 college credits awarded through the program. 7. During the year 2003, Respondent fraudulently submitted the 6 credits from Eastern Oklahoma State College (EOSC) through the MOTET program to renew her certification in the subject area of English. The MOTET courses required no work or a minimum amount of work or academic effort and Respondent knew or should have known that the cotirses were not sufficient to satisfy renewal requirements. The Petitioner charges: STATUTE VIOLATIONS COUNT i: The Respondent is in violation of Section 1012.795(1)(a), Florida Statutes, in that Respondent obtained or attempted to obtain a teaching certificate by fraudulent means. COUNT 2: The Respondent is in violation of Section 1012.795(1)(g), 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 3: The Respondent is in violation of Section 101 2.795(1)(), 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 4: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(4)(b), Florida Administrative Code, in that Respondent has intentionally distorted or misrepresented facts concerning an educational matter in direct or indirect public expression. COUNT 5: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(5)(a), Florida Administrative Code, in that Respondent bas failed to maintain honesty in all professional dealings. (SIGNATURE ON FOLLOWING PAGE) LINDA ASHLEY Administrative Complaint Page 3 of 3 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; determining the Respondent to be ineligible for certification; or barring the Respondent from reapplying for an educator’s certificate for a period of time up to 10 years or permanently. on this hata Gay EXECUTED on this JU day or Anaust 2009, 7s) DR. ERIC J/SMITH, as Commissioner of Education State of Florida

Docket for Case No: 11-000235PL