STATE OF FLORIDA %, DEPARTMENT OF HEALTH Ls DEPARTMENT OF HEALTH Petitioner, O07 / 6 4 ,% vs. Case No. 97-20906 % YVONNE DENNIS TUCKER, ? Respondent. / 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, YVONNE DENNIS TUCKER, 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 1409602. | 4. Respondent's last known address is 1275 NE 202nd Street, Miami, Florida 33179. i pee nn ee peer ee e cpg pes cee ene, eee ee RR ETE RRR oR tree a pee eee apne et ay BG 5. At all times material hereto, Respondent was employed by Jackson North Maternity Center. 6. In or about April 1997, Respondent assisted Dr. Paul Norris in a_ circumcision of an infant. 7. During the circumcision, Respondent moved her hand back and forth over the infant stating the following: "I know what you're thinking”. 8. In or about April 1997, Respondent met with nurse Eunice Madrigal and the following events took place: . a. Respondent approached Madrigal and stared directly in to Madrigal's eyes; b. Respondent began stomping her foot and clapping her hands; and c. Respondent began stating: "Satan get away from me because Jesus loves me." 9. Both of the aforementioned events were reported to the Respondent's employer. 10. Respondent's behavior during both events was unprofessional and not — appropriate for the workplace. 11. Respondent was referred to her employer's Employee Assistance Program _ EAP) for help. | 12. After interviewing the Respondent, Anthony Fallon, E.A.P Coordinator, _ opined that the Respondent should undergo a complete psychiatric evaluation for determination if the Respondent is safe to return to practice. . 13. Respondent failed to undergo the requested psychiatric evaluation. 14. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, 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 (Maay of Raw g , 1998 Robert G. Brooks, MD Secretary, Department of Health BY: NandéySnifkowski, Chief Attorney . On Behalf of the Agency for Health Care Administration COUNSEL FOR THE PETITIONER: PePMGEPUTY OF HEALTH Reginald D. Dixon, Senior Attorney ; FBN: 0112925 crenkpptiohameQ, Oumr __ Agency for Health Care Administration DATE U- G-A®A i Tallahassee, Florida 32317-4229 - (850) 414 - 8576 vy RDD/td PCP: LS \ uN DOM: ca\ay\a% ol CORR err rer gene pe rege meme ne

Docket for Case No: 00-001636