STATE OF FLORIDA EDUCATION PRACTICES COMMISSION TOM GALLAGHER, as Commissioner of Education, Petitioner, vs. HEIDI M. CARTON, Respondent. CASE NO. 989-1974-M 00-412) PL ADMINISTRATIVE COMPLAINT Petitioner, TOM GALLAGHER, as Commissioner of ucation, files this Administrative Complaint against Heidi M. Carton. The Petitioner seeks the apptopriate disciplinary sanction of the Respondent’s educator’s certificate pursuant to Sections 231.262| and 231.28, Florida Statutes, and pursuant to Rule 6B-1.006, Florida Administrative Code, Principles of Professional Conduct for the Education Profession in Florida, said sanctions specifically set forth in Sections 23 1.262(6) and 231.28(1), Florida Statutes. ; The Petitioner alleges: JURISDICTION 1. The Respondent holds Florida Educator’s Certificate 771267, covering the area of Elementary Education, which is valid through June 30, 2004. 2. At all times pertinent hereto, the Respondent was e! at Vero Beach High School, in the Indian River County School Dist MATERIAL ALLEGATIONS 3. During February 1998, Respondent failed to proper! school trip to New Orleans. Respondent acted improperly when sh LSD and alcohol during the trip and even participated in the smo Respondent also participated with several female students in expo: ployed as a Social Science teacher ict. supervise students who attended a allowed students to use marijuana, ing of marijuana with the students. ing their breasts during Mardi Gras events to get beads. Respondent also violated school board policy when she allowed two unauthorized adults to participate in the field trip. Heidi M. Carton Administrative Complaint Page 2 of 2 COUNT 1: The allegations of misconduct set forth herein are in violation of Section 231.28(1)(c), Florida Statutes, in that Respondent has been guilty of Bross immorality or an act involving moral turpitude. COUNT 2: The allegations of misconduct set forth |herein are in violation of Section 231.28(1)(f), Florida Statutes, in that Respondent, upon investigatiqn, has been found guilty of personal conduct which seriously reduces her effectiveness as an employee of the’school board. COUNT 3: The allegations of misconduct set forth herein are in violation of Section 231.28(1)(i), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession in Florida prescribed by State Board of Education. RULE VIOLATIONS COUNT 4: The allegations of misconduct set forth erein are in violation of Rule 6B- 1.006(3)(a), Florida Administrative Code, in that Respondent hag failed to make reasonable effort to protect the student from conditions harmful to learning and/or to the stident’s mental health and/or physical safety. . COUNT 5: The allegations of misconduct set forth erein are in violation of Rule 6B- 1.006(3)(e), Florida Administrative Code, in that Respondent has intentionally exposed a student to unnecessary embarrassment or disparagement. COUNT 6: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(h), Florida Administrative Code, in that Respondent has ¢xploited a relationship with a student for personal gain or advantage. WHEREFORE, the Petitioner recommends that the Education Practices Commission impose an appropriate penalty pursuant to the authority provided in Sections 231.262(6) and 231.28(1), Florida Statutes, which penalty may include a reprimand, probation, restriction of the authorized scope of practice, administrative fine, suspension of the teaching certificate not to exc ed three years, permanent revocation of the teaching certificate, or combination thereof, for the reasons set forth herein, and in accordance with the Explanation and Election of Rights forms which are attached hereto and made a part hereof by reference. —H EXECUTED on this__ 6 ‘day of TOM GALLAGHER, mmissioner of Education, State of Florida

Docket for Case No: 00-005121PL