STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, VS. CASE NO. 112-2678 CAROLYN WRIGHT CLARK, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against CAROLYN WRIGHT CLARK. The Petitioner seeks the appropriate disciplinary sanction of tle Respondent’s educator’s certificate pursuant to Sections 1012.31, 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), Blorida Statutes. The Petitioner alleges: JURISDICTION 1, The Respondent holds Florida Educator's Certificate.448445, covering. the. areas of Elementary Education, English for Speakers of Other Languages (ESOL), Psychology and Reading, which is valid through June 30, 2017. 2, At all times pertinent hereto, the Respondent was employed as a First Grade Teacher at Dr. Robert B. Ingram Elementary School in the Miami-Dade County School District. MATERIAL ALLEGATIONS 3, During the 2011-2012 school year, the Respondent inappropriately disciplined first grade students by grabbing and pushing students by their clothing/back area. The Petitioner charges: STATUTE VIOLATIONS COUNT I: The Respondent is in violation of Section 1012.795(1)(), Florida Statutes, CAROLYN WRIGHT CLARK Administrative Complaint Page 2 of 2 in that Respondent has violated the Principles of Professional Conduct for the Education Profession prescribed by State Board of Education rules. RULE VIOLATIONS COUNT 2: 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. 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. 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 certifica 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 educatar’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; deter: mining the Respondent to be certificate for a period of time up to 10 years or permanently. EXECUTED on this 2 1 day of Ages \ , 2014, Luthar, PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 15-004990PL