STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, vs. CASE NUMBER: 98-17905 STEVEN D. FLOWERS, Cy 0200 RESPONDENT. ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as “Petitioner,” and files this Administrative Complaint before the Board of Pharmacy against STEVEN D. FLOWERS, hereinafter referred to as “Respondent,” and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of pharmacy pursuant to Section 20.43, Florida Statutes (Supp. 1996); Chapter 455, Florida Statutes; and Chapter 465, Florida Statutes. Pursuant to the authority of Section 20.43 (3)(g), Florida Statutes, the Petitioner has contracted with the Agency of Health Care Administration to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quality Assurance, councils, or boards, as appropriate. 2. Respondent is, and has been at all times material hereto, a licensed pharmacist in the State of Florida, having been issued license number PS 0030616. Resp¢=Jent’s last known address is 241 Lincolnshire Road, Winter Park, Florida 32792-4339. ca ca 3. On or about July 16, 1998, the Indiana Board of Pharmacy “suspended indefinitely” Respondent’s license to practice as a pharmacist based on a for-cause drug screen done on or about October 11, 1997, while Respondent was working as a pharmacist at St. Vincent’s Hospital, Indianapolis, Indiana, which reflected positive for alcohol in the concentration of 0.04%. 4. The drug screen was initiated after a nurse working with Respondent noticed the smell of alcohol on his breath and that he was withdrawn and dropped several items while assisting with a situation in the cardiac unit. 5. Respondent denies that he acted any way other than professional, and stated that he would never have placed any patient’s life in jeopardy. Respondent stated that at best he is a social drinker and certainly not an addict. 6. Based on the foregoing, Respondent is subject to discipline for violating Section 465.016(1)(d)(1), Florida Statutes by being unfit or incompetent to practice pharmacy by reason of habitual intoxication. WHEREFORE, Petitioner respectfully requests the Board of Pharmacy enter an order imposing one or more of the following penalties: revocation or suspension of the Respondent’s license, restriction of the Respondent's practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. VU Se Ne . SIGNED this 4A {A day of | 9 lenwla~ _, 1999. Robert G. Brooks, Secretary, Department o Nancy M. Snurkowski Chief Attorney ; Agency for Health Care Administration __ COUNSEL FOR PETITIONER: CH Carolyn Taylor, Attorney Agency for Health Care Administration Ss Allied Health i P.O. Box 14229 = Tallahassee, FL 32317-4229 moe (850) 487-9690 — CT/Amh . 2 og PCP: Wood and Stamitoles / LI¢«MS Tw DATE: December 15, 1998 U2 las mm a ge FILED DEPARTMENT OF HEALTH EPUTY CLERK CLERK Hpophone ne oate_/0 4-29 aT

Docket for Case No: 00-000380