STATE OF FLORIDA EDUCATION PRACTICES COMMISSION RICHARD CORCORAN, as Commissioner of Education, Petitioner, vs. CASE NO. 189-3522 CAROLINA SIMON, Respondent. ADMINISTRATIVE COMPLAINT 7 Petitioner, Richard Corcoran, as Commissioner of Education, files this Administrative Complaint against CAROLINA SIMON. 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 829897, covering the areas of English and Social Science, which is valid through June 30, 2021. 2. At all times pertinent hereto, the Respondent was employed as a Social Science Teacher at Loggers Run Middle School in the Palm Beach County School District. MATERIAL ALLEGATIONS 3. During the 2018-2019 school year, Respondent failed to follow district fundraising guidelines and failed to fully inform her principal of the details of a fundraiser she was proposing. Respondent sent a notice of the fundraiser on school letterhead with a facsimile of her principal's signature when the principal had neither seen the document nor signed it. 4. Respondent improperly used her institutional privileges for personal gain when she misrepresented the fundraiser as being a school function, sent notices to parents on school letterhead with what appeared to be the principal's signature and used a promise of display of Probable Cause Letter and Administrative Complaint.-2 CAROLINA SIMON Administrative Complaint Page 2 of 3 student projects as a draw to attract donors. The fundraiser was in fact to benefit a limited liability corporation owned and operated by Respondent and her husband. While Respondent promised that a donation would be made to the school, there was no written agreement in place and no requirement of accountability of funds collected. 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)(b)2, Florida Administrative Code, in that Respondent has intentionally distorted or misrepresented facts concerning an educational matter in direct or indirect public expression. COUNT 4: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(2)(b)3, Florida Administrative Code, in that Respondent has used institutional privileges for personal gain or advantage. COUNT 5: 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. (SIGNATURE ON FOLLOWING PAGE) Probable Cause Letter and Administrative Complaint.-3 CAROLINA SIMON 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 phe day of November _, 2020. fh kMli- RICHARD CORCORAN, as Commissioner of Education State of Florida Probable Cause Letter and Administrative Complaint.-4

Docket for Case No: 21-001591PL