STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 134-2208 VIRCEL LYNETTE WILLIAMS, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against VIRCEL LYNETTE WILLIAMS. 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: JURISDICTION 1. The Respondent holds Florida Educator’s Certificate 658148, covering the areas of Educational Leadership, Elementary Education, English for Speakers of Other Languages (ESOL) and Exceptional Student Education, which is valid through June 30, 2017. 2. At all times pertinent hereto, the Respandent was employed as a Behavior Specialist at James Stephens International Academy in. the Lee County School District. MATERIAL ALLEGATIONS a 3. During the 2013/2014 school year, Respondent failed to provide appropriate services for Exceptional Education Students (ESE) enrolled at her school. Respondent's conduct included but was not limited to: a) On or about September 11, 2013, Respondent held an IEP meeting for D.M., a male, middle school, ESE student who was new to the school and came with an IEP identifying a Service Delivery Model (SDM) of Supportive Behavior (SB) for VIRCEL LYNETTE WILLIAMS Administrative Complaint Page 2 of 3 D.M. requiring that he be placed in a small class with a certified ESE teacher. During the IEP meeting, D.M.’s teachers voiced the need for a restrictive environment for D.M. based on violence and inappropriate touching of another student. Ignoring the previous IEP and the recommendations of his teachers, Respondent changed D.M.’s SDM to Collaborative Teaching (CT) which allowed her to place D.M. in the general student population. Respondent had the [EP signed by an elementary general education teacher who was not at the [EP meeting and who had no interaction with D.M. Additionally, the change was implemented prior to notification of the D.M.’s parents. b) Respondent changed the IEPs of multiple students who had previously been classified SB to CT without convening an IEP meeting or contacting the students’ parents. c) The above referenced students were placed in the general student population contributing to behavior issues including violence and inappropriate sexual conduct that resulted in students being placed in alternative programs. 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 effectiveness as an employee of the school board. COUNT 2: The Respondent is 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 3: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081G)(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. (SIGNATURI a3] ON FOLLOWING PAGE) VIRCEL LYNETTE WILLIAMS 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. EXECUTED on this (2™ aay or October, 2015. PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 16-001654PL