U U STATE OF FLORIDA - DEPARTMENT OF HEALTH —«- 9 JAN 18 PM id: gs : OW Sie ae DEPARTMENT OF HEALTH . . : ADMINS TRA. VE ee HEARINGS ~ Petitioner, ¥S. Case No. 98-21200 MICHELE RENE BROOKS, — 0 0-2 pa Respondent, , / TRAT. Cc L COMES NOW, Petitioner, DEPARTMENT OF HEALTH, by and through its undersigned counsel and files this administrative complaint before the Board of Nursing against the Respondent, MICHELE RENE BROOKS, and in support thereof alleges: | 1. Petitioner is the state agency charged with regulating the practice of nursing pursuant to Chapters 20, 455, and 464, Florida Statutes. 2. Pursuant to the authority of Section 20.43(3)(g), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration to provide consumer complaint, investigative and prosecutorial services required by the Division of Medical Quality Assurance, councils or boards, as appropriate, including the issuance of emergency orders of suspension or restriction. 3. Respondent is and has been at all times material hereto, a licensed REGISTERED NURSE in the State of Florida, having been issued license number RN 2683382. 4. Respondent's last known address is 19692 Bluebird Lane #18, Fairhope, AL 36532, U U ‘5. -Réspondent was employed by Santa Rosa Medical Center when she was observed with the smell of alcohol on her breath. 6. Respondent was requested to submit to a drug/alcohol screen. 1 Respondent's sample tested positive for alcohol 8. Respondent was referred to the Intervention Project for Nurses (IPN), a monitoring and referral program for impaired nurses, and began monitoring. 9. While being monitored by IPN, Respondent tested positive for Marijuana ‘on an IPN requested drug screen; Respondent admitted to using Marijuana. 10. While being “monitored by IPN, Respondent tested positive for Proxyphene on an IPN requested drug screen. 11. Both Marijuana and Propoxyphene are controlled substances under chapter 893, Florida Statutes. 12, Respondent was eventually dismissed from IPN due to issues of noncompliance with IPN directives. 13. Respondent's use of alcohol and/or controlled substances affects her - ability to practice nursing with reasonable skill and safety. 14.. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)@), Florida Statutes, by being unable to practice nursing with reasonable skill and safety to patients due to the use of drugs and/or narcotics. WHEREFORE, Petitioner respectfully request that the Board of Nursing enter an Order imposing one or more of the following penalties: Revocation or suspension of Respondent's license, imposition of an administrative fine, issuance of a reprimand, UY placement of thie Respondent on probation, costs, and/or any other relief that the Board deems appropriate. Signed Highs day of | ; UY _, 1999 Robert G. Brooks, M.D. Secret BY: COUNSEL FO} Reginald D. Di FBN: 0112925 Agency for Health Care Administration Allied Health Section Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 RDD/d = PCP: CO\AL S:\Nursing\ACs\ac98-21200.doc | PETITIONER: Senior Attorney , Department of Health Nancy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration DOM: dloalag | FILED DEPARTMENT OF HEALTH EPUTY CLERK cempigonrd um pate 26-55

Docket for Case No: 00-000285