STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, VS. CASE NO. 178-1676 ERINN MORIARTY, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against ERINN MORIARTY. 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 1268934, covering the area of Social Science, which was valid through June 30, 2017. MATERIAL ALLEGATIONS Ds In or around June of 2017, Respondent submitted fraudulent information to the Georgia Professional Standards Commission for purposes of obtaining a Georgia Educator’s Certificate. Respondent submitted a copy of a fraudulent Florida Professional Educator’s Certificate purportedly issued to Respondent; however, Respondent did not hold a Florida Professional Educator’s Certificate. Respondent affirmed on the Georgia application that all documents submitted were “true, complete and correct.” The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of section 1012.795(1)(a), Florida Statutes, ERINN MORIARTY Administrative Complaint Page 2 of 2 in that Respondent obtained or attempted to obtain a teaching certificate by fraudulent means. COUNT 2: 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 3: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(2)(c)1, Florida Administrative Code, in that Respondent has failed to maintain honesty in all professional dealings. COUNT 4: The Respondent is in violation of Rule 6A-10.081(2)(c)7, Florida Administrative Code, in that Respondent has misrepresented her professional qualifications. COUNT 5: The Respondent is in violation of Rule 6A-10.081(2)(c)8, Florida Administrative Code, in that Respondent has submitted fraudulent information on a document in connection with professional activities. 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 23% day of (Y\ AY 2018. PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 19-003635PL