STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 112-3347 PATTI ROSE WITHERS, Respondent, ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against PATTI ROSE WITHERS. 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 6A-10.081, 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: JORISDICTION lL. The Respondent holds Florida Educator’s Certificate 795790, covering the areas of World Language - French, History and Reading, which is valid through June 30, 2015, 2. At all times pertinent hereto, the Respondent was employed as a Reading Teacher at Wiregrass Ranch High School in. the Pasco County School District. MATERIAL ALLEGATIONS 4 3. On or about October 26, 2011, the Respondent acted erratically while supervising and instructing students in her class. Specifically: {a) the Respondent told an assistant principal that “I need someone to tell these kids to fucking shut up,” or words to that effect; (b) the Respondent stated “I quit” several times; and PATTI ROSE WITHERS Administrative Complaint Page 2 of 3 (c) the Respondent walked outside of the classroom, dropped to the ground and purposefully struck her head on a concrete wall, 4, The Respondent's conduct as alleged in Paragraph 3 was witnessed by several students and members of the school staff. 5. The Respondents’s conduct as alleged in Paragraph 3 was reported on in the local print media. 6. On or about June 5, 2012, the Respondent submitted her resignation to the Pasco County School District. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: 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 2: The Respondent is in violation of Section 1012.795(1)(j), 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 3: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(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. GIGNATURE ON FOLLOWING PAGE) PATTI ROSE WITHERS 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, arty 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. 4h Pan EXECUTED on this 12°" gayor August 2013. he, Lececrf PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 14-003088PL