€~ STATE OF FLORIDA ‘ DEPARTMENT OF HEALTH DEPARTMENT. OF HEALTH - Petitioner, vs. a, Case No. 1999-03736 PAULINE C. MCBEAN MORRIS, : 00-FOW PL . Respondent. . J 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, PAULINE C. MCBEAN MORRIS, 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 $tatutes. | 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 licenseti REGISTERED NURSE in the State of Florida, having been issued license number RN 1667222. anny ab Int 4. Respondent's last known address 6830 SW 36th Street, Miramar, Florida 33023-6017. . 5. On or about March 11, 1999, While working at the Cedars Medical Center, Respondent practiced below the minimal acceptable standards] of prevailing nursing practice by administering medications or treatments in a negligent manner, to patients under her care, to wit: Respondent administered 4 mg. of Vincristine to Patient P.V. instead of the physician ordered 0.4 mg. 6. 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 (2Aheay of” , 2000). Robert G. Brooks, M.D. D Sacretary, Department of Health DEPARTMENT OFH J DEPUTY CLERK 7 CLERK Uehi R. Ltn on baT [97 Poon BY: = Mancy Snurkowski, Chief Attorney &__}-(¥7 700 On Behalf of the Agency for — Health Care Administration rOsl VITICS DUA 142297 Tallahassee, Florida 32317-4229 (850) 414 - 8437 ‘ RDD/rd

Docket for Case No: 00-005064PL