STATE OF FLORIDA EDUCATION PRACTICES COMMISSION DR, ERIC J. SMITH, as Commissioner of Education, Petitioner, vs. CASE NO. 101-1861 CARMEN KEELING, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Dr. Eric J. Smith, as Commissioner of Education, files this Administrative Complaint against CARMEN KEELING. The Petitioner seeks 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 916499, covering the area of Guidance and Counseling, which is valid through June 30, 2011. 2. At all times pertinent hereto, the Respondent was employed as an English for Speakers of Other Languages Community Language Facilitator at L.C. Swain Middle School in the Palm Beach County School District. MATERIAL ALLEGATIONS 3. In 2004, the Respondent submitted two Florida Teacher Certification Score Reports to the Palm Beach County School District in order to document her qualification for certification and employment. Specifically, the Respondent submitted: (a) a Score Report dated August 13, 2003, indicating passing scores in Middle Grades Integrated Curriculum Subject Area Exam, Professional Education Exam and General Knowledge Exam Subtests in Math, Reading, English and Essay; and Filed January 17, 2012 10:36 AM Division of Administrative Hearings CARMEN KEELING Administrative Complaint Page 2 of 3 (b) a Score Report dated June 11, 2003, indicating a passing score for Middle Grades Mathematics Subject Area Exam. 4, The documentation submitted by the Respondent did not properly reflect the Respondent’s actual scores. The Respondent did not pass any of the exams listed in the reports that she submitted. 5. The Respondent submitted altered Score Reports in an attempt to document her qualification for certification and employment. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1)(d), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude as defined by rule of the State Board of Education. COUNT2: The Respondentis in violation of Section 1012.795(1)Q), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession prescribed by State Board of Education rules. RULE Vi ONS COUNT 3: 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 in all professional dealings. COUNT 4: — The Respondent is in violation of Rule 6B-1.006(5)(g), Florida Administrative Code, in that Respondent has misrepresented her professional qualifications. RAR 7S in OF RWC Ob-1 AaCMINIS Code, in that Respondent has submitted fraudulent information on a document in connection with professional activities. COUNTS: The Respondentis in violation of Rule 6B-1.006(5)(h), Florida Administrative COUNT6: The Respondentis in violation ofRule 6B-1.006(5)(i), Florida Administrative Code, in that Respondent made a fraudulent statement or failed to disclose a material fact in her own or another’s application for a professional position. (SIGNATURE ON FOLLOWING PAGE) CARMEN KEELING 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. : 1 EXECUTED on this Te day of LAVLe , 2011. Commissioner of Education State of Florida

Docket for Case No: 12-000182PL