STATE OF FLORIDA EDUCATION PRACTICES COMMISSION GERARD ROBINSON, as Commissioner of Education, Petitioner, vs. CASE NO. 090-1177 FARRAH ELLER RYALS, Respondent. / ADMINISTRATIVE COMPLAINT ° Petitioner, Gerard Robinson, as Commissioner of Education, files this Administrative Complaint against FARRAH ELLER RYALS. 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 813653, covering the areas of English for Speakers of Other Languages (ESOL), Pre~Kindergarten/Primary Education, School Social Worker, and Exceptional Student Education, which was valid through June 30, 2011. 2. At all times pertinent hereto, the Respondent was employed as a Kindergarten Teacher at West Elementary School in the Desoto County School District. MATERIAL ALLEGATIONS 3. On or about October 19, 2009, the Respondent left the school campus in her vehicle during the school day and met an individual in the parking lot of a retail store. The Respondent purchased a small amount of cocaine from the individual. The Respondent was detained by law enforcement and attempted to conceal a plastic baggie containing cocaine on her person. The law enforcement officers discovered the cocaine and arrested the Respondent for Possession of Cocaine and Possession of Paraphernalia. FARRAH ELLER RYALS Administrative Complaint Page 2 of 3 4, On or about October 19, 2009, the DeSoto County School District suspended the Respondent without pay. 5. On or about August 20, 2010, the Respondent entered into a pretrial diversion contract with the State Attorney for an 18 month period. On or about June 3, 2011 the charges were dismissed upon the Respondent’s completion of the program. 6. On or about March 4, 2011, the DeSoto County School District terminated the Respondent from her employment. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1)(d), Florida Statutes, in that Respondent bas been guilty of gross immorality or an act involving moral turpitude as defined by rule of the State Board of Education. 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. COUNT3: The Respondents in violation of Section 1012.795(1)G), 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) FARRAH ELLER RYALS 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 Respendent’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. EXECUTED on this | OO gay of Flowers _. 2047. taand. Commissioner of Education State of Florida

Docket for Case No: 13-000244PL