STATE OF FLORIDA EDUCATION PRACTICES COMMISSION RICHARD CORCORAN, as Commissioner of Education, Petitioner, vs. CASE NO. 178-2606 PAMELA ANN VICKARYOUS, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Richard Corcoran, as Commissioner of Education, files this Administrative Complaint against PAMELA ANN VICKARYOUS. 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 748547, covering the areas of Educational Leadership, Elementary Education, English for Speakers of Other Languages (ESOL) and Reading, which is valid through June 30, 2022. 2. At all times pertinent hereto, the Respondent was employed as a Principal at Manatee Middle School in the Collier County School District. MATERIAL ALLEGATIONS 3. Over the course of Respondent’s tenure as principal, from 2013 through the 2017/2018 school year, her conduct of bullying and humiliating educators serving under her created a hostile work environment that interfered with the educators’ ability to perform the duties of their jobs. Respondent’s conduct included but was not limited to: a) During October of 2018, Respondent entered the classroom of teacher Madison Squiglia, who had recently been dealing with health issues, and Respondent told teacher Squiglia PAMELA ANN VICKARYOUS Administrative Complaint Page 2 of 3 that no one at the school cared about her and that teacher Squiglia was an embarrassment to the school due to her recent showing of enthusiasm for the basketball team Squiglia coached. b) Respondent recorded private conversations between educators and installed video equipment directed at teachers rather than students. c) Respondent, on a regular basis, belittled and humiliated educators to the point of bringing the educators to tears. d) Respondent insisted that educators in her school inform her if they applied for other jobs and if the educators did apply for other jobs, Respondent would target them by subjecting them to extra observations and evaluations. e) The day after assistant principal (AP) Jessica Duesler complained to the district human resources department about Respondent’s intimidating tactics, Respondent yelled at and threatened AP Duesler and gave Duesler a task list with “an impossible number of tasks.” f) Respondent refused to provide AP Carey Gilcher with appropriate training or support and then told AP Gilcher that others were not satisfied with her performance. g) Respondent intimidated, belittled and demeaned multiple other educators who became the targets of Respondent’s rage and retaliation. 4. Respondent’s conduct resulted in numerous educators at her school seeking employment elsewhere. During the period from June 1, 2017, to November 30, 2017, twelve employees left the school and three more were pending resignation. 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)(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(2)(c)4, Florida Administrative Code, in that Respondent has engaged in harassment or FERS PAMELA ANN VICKARYOUS Administrative Complaint Page 3 of 3 discriminatory conduct which unreasonably interfered with an individual’s performance of professional or work responsibilities or with the orderly processes of education or which created a hostile, intimidating, abusive, offensive, or oppressive environment; and further, failed to make reasonable effort to assure that each individual was protected from such harassment or discrimination. 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 31 day of July : , 2019. A RICHARD CORCORAN, as | Commissioner of Education State of Florida FEBR4

Docket for Case No: 19-005641PL