STATE OF FLORIDA EDUCATION PRACTICES COMMISSION GERARD ROBINSON, as Commissioner of Education, Petitioner, vs. CASE NO. 101-2826 MARGARET M. ANDREWS, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Gerard Robinson, as Commissioner of Education, files this Administrative Complaint against MARGARET M. ANDREWS. 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 786322, covering the areas of English for Speakers of Other Languages (ESOL), Middle Grades Integrated Curriculum, Reading and Specific Learning Disabilities, which is valid through June 30; 2014: 2. Atall times pertinent hereto, the Respondent was employed as an Intensive Reading Teacher at Landrum Middle School in the St. Johns County School District. MATERTAL ALLEGATIONS 3, On or about December 15,2010, in Duval County, Florida, Respondent was involved in a traffic crash in which she drove her vehicle into a ditch. Law enforcement officers noted that Respondent appeared to be intoxicated, Respondent refused to participate in field sobriety exercises, and her breath alcohol level was measured at .246. Respondent was arrested and charged with Driving Under the Influence. On or about June 27, 2011, Respondent pled nolo contendere to, and was adjudicated guilty of Driving Under the Influence. Filed April 24, 2012 9:09 AM Division of Administrative Hearings MARGARET M. ANDREWS Administrative Complaint Page 2 of 3 4, On or about Thursday, April 7, 2011, Respondent tested positive for Ethanol after having been on school grounds, during school hours. 5. On or about Wednesday, April 13, 2011, Respondent again tested positive for Ethanol after having been on school grounds, during school hours. 6. On or about April 25, 2011, Respondent resigned in lieu of termination from her teaching position with the district. 7. The Respondent is in violation of Section 1012.795(2), Florida Statutes, which provides that the plea of guilty in any court or the decision of guilty by any court is prima facie proof of grounds for the revocation of the certificate. 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 Siate Board of Education. COUNT 2: The Respondent is in violation of Section 1012.795(1)(f), Florida Statutes, in that Respondent has been convicted or found guilty of, or entered a plea of guilty to, regardless of adjudication of guilt, a misdemeanor, felony, or any other criminal charge, other than a minor traffic violation. COUNT3: The Respondent is in violation of Section 1012.795(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(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. (SIGNATURE ON FOLLOWING PAGE) MARGARET M. ANDREWS 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. GERARD ROBINSON, as Commissioner of Education State of Florida

Docket for Case No: 12-001527PL