STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, ' «2 vs. . Case No. 99-0370 JUDITH E. SNYDER, Respondent. OD- 03 b 7 / ADMINISTRATIVE COMPLAINT 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, JUDITH E. SNYDER, 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 2719472. 4. Respondent's last known address is 2275 SE 5th Court, Homestead, Florida 33033 U mo — ) 5. At all times material hereto, Respondent was employed by South Miami Hospital. 6. On or about March 3, 1999, Respondent administered Versed and Fentanyl to Patient J.J. 7. On or about March 3, 1999, Patient J.J. did not have a physician's order for Versed or Fentanyl to be administered. 8. Respondent violated the minimal acceptable standards of prevailing nursing practice by administering medications to a patient that did not have physician's orders for those medications. 9. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, by unprofessional conduct by failing to conform to the minimal acceptable standards of prevailing nursing practice. 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, placement of the Respondent on probation, costs, and/or any other relief that the Board deems appropriate. Signed this Y Nday of K Md \OAn A lhe, Robert G: Brooks, M.D. Secretary, Department of Health BY: — Nancy Snurko ; Chief Attorney On Behalf of the Agency for Health Care Administration FILED DEPARTMENT OF HEALTH EPUTY CLERK CLERK Q. pate M15 99 COUNSEL FOR THE PETITIONER: Reginald D. Di¥dn, Senior Attorney FBN: 011292 Agency for Heajth Allied Health S¢ction Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 RDD/rd pcp: L2vAmM DOM: vof ht 7 S:\Nursing\Administrative Complaints\ac-snyder-j.doc e Administration

Docket for Case No: 00-000367