% STATE OF FLORIDA - DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, - Petitioner, vs. . . CASE NO.: 96-16548 JANIS LOUISE McKEEHAN, Respondent. / na ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF HEALTH, hereinafter referred to as “Petitioner,” files this Administrative Complaint before the Board of Nursing against JANIS LOUISE McKEEHAN, hereinafter referred to as “Respondent,” and alleges: . 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of nursing pursuant to Section 20.43, Florida Statutes (Supp. 1996); Chapter 455, Florida Statutes; and Chapter 464, Florida Statutes. ; 2. . Pursuant to the authority of ‘Section 20.43(3)(), Florida Statutes (Supp. a 1996), 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 a issuance of emergency orders of suspension 0 or restriction. 3. Respondent is, and has ‘been at all times inaterial hereto, a License Practical Nurse, having been issued license number PN 0834141. u ND 4. Respondent’s last known address is 2312 Britannia Road, Sarasota, Florida 34231-4144. - 5. On or about May 25, 1992, Respondent inflicted second-degree bums on her infant child by placing the infant over a hot burner of a kitchen stove. Respondent admitted to intentional child abuse. In criminal ¢ case '9212539FA, Respondent entered a plea of nolo contendere to the offense of child abuse by culpable negligence with weapon causing great bodily harm, in violation of Chapter 827.07/775.087, Florida Statutes. Respondent was placed on ten (10) years probation beginning on October 13, 1992. 6. The aforementioned crime directly relates to Respondent’s ability to practice nursing or to the ability to practice nursing. 7. Respondent also failed to notify the Board of Nursing with a change of address within sixty (60) days of said change. COUNT I 8. Petitioner realleges and incorporates by reference the allegations contained in the foregoing paragraphs as if fully stated herein. . 9. Based on the foregoing, the Respondent’s license to practice nursing in the State of Florida j is subj t to discipline Pursuant to Section 464. FOIE), Florida Statutes, by being found guilty, regardless of adjudication, of a crime in 1 any jurisdiction which directly relates to the practice of nursing or to the ability to practice nursing. _ “CO - 10. Petitioner realleges and incorporates by reference the allegations contained "in the foregoing paragraphs as if fully stated herein. cee nipecgerene trae tte Ww wd 11 Based on the foregoing, the Respondent's license to practice nursing in the State of Florida is subject to discipline pursuant to Section 464.018(1)(d)5, Florida - Statutes, by being found guilty, regardless of adjudication, of a violation of Chapter 784, relating to assault, battery, and culpable negligence. Oo ~ COUNTIN 12.Petitioner realleges and incorporates by reference the allegations contained in’ the foregoing paragraphs as if fully stated herein. . “13. Based ¢ on the foregoing, the Respondent s license to Practice nursing in the State of Florida is subject to discipline pursuant to Section 464.01 gc1y(ae, Florida Statutes, by being found guilty, regardless of adjudication, of a violation of Chapter 827, - relating to child abuse. | COUNT IV 14. Petitioner rellege and incorporates by reference the allegations contained ~ inthe foregoing paragraphs as if fully stated herein. - 15. Based on 1 the : forego the Respondent’ S ‘license to practice nursing in the state of Florida 4 is subject to disipline pursuant « to Section 455. 624(1)(q), Florida Statutes, by “Violating a “Rule 64B9-1. 015, Florida “Administrative Code, by ‘failing to notify the Board of Nursing of a change of address within sixty (60) days of said change. WHEREFORE, Petitioner respectfully requests the Board of Nursing enter an Order imposing one or more of the following penalties: suspension of license, imposition of an administrative fine not to exceed $1,000 for each offense, issuance of a reprimand, eee: VW placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. COUNSEL FOR AGENCY: Reginald Di Dixon Staff Attonte Florida Bar'Number 0112925 Agency for Health Care Administration General Counsel’s Office - MQA - Allied Health P.O. Box 14229 Tallahassee, FL 32317 - 4229 (850) 487-9637 RDD/SB/kmg PCP: Boyel £ Malasanos J SIGNED tis Bvdey of _ Shh io 1998. Douglas M. Cook Director 5 : Nancy M. Snurkowski Chief Attorney On Behalf of the Agency for Health Care Administration MENT OF HEALTH OER TY cu ERK LERK AAAS! Q. C ‘ c Ay © 5 g pate__JO 7 = Doms 4-30-48

Docket for Case No: 00-000747