Petitioner: CHARLIE CRIST, AS COMMISSIONER OF EDUCATION
Respondent: CAROL A. HOSKINS
Judges: ROBERT E. MEALE
Agency: Department of Education
Locations: Orlando, Florida
Filed: Feb. 18, 2003
Status: Closed
Settled and/or Dismissed prior to entry of RO/FO on Monday, June 16, 2003.
Latest Update: Jan. 11, 2025
STATE OF FLORIDA fm ft fos
EDUCATION PRACTICES COMMISSION OF Fp “hy /)
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CHARLIE CRIST, as Dy PH 2:00
Commissioner of Education, ADK 0H he
BA atte 7 VE
Petitioner, eG
vs. : CASE NO. 012-0289-M
0 O56) PL
CAROL A. HOSKINS,
Respondent.
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ADMINISTRATIVE COMPLAINT
Petitioner, Charlie Crist, as Commissioner of Education, files this Administrative Complaint
against CAROL A. HOSKINS. The Petitioner seeks the appropriate disciplinary sanction of the
- Respondent’s Educator’s Certificate pursuant to Sections 231.262 and 231.2615, Florida Statutes,
and pursuant to Rule 6B-1.001, Florida Administrative Code, Code of Ethics of the Education
Profession in Florida, and Rule 6B-1.006, Florida Administrative Code, Principles of Professional
Conduct for the Education Profession in Florida, said sanctions specifically set forth in Sections
231.262(7) and 231.2615(1), Florida Statutes.
The Petitioner alicges:
JURISDICTION
1. The Respondent holds Florida Educator’s Certificate 533437, covering the areas of
Administration and Supervision, Early Childhood Education and Elementary Education, which is
valid through June 30, 2005.
2 At all times pertinent hereto, the Respondent was employed as a Second Grade
teacher at Lockhart Elementary School in the Orange County School District.
MATERIAL ALLEGATIONS
3. On or about May 12, 1999, the Respondent behaved inappropriately with a colleague,
Edward Smith. She shoved him during a disagreement. On or about April 12, 2000, she entered into
a Settlement Agreement with the school board, conditions of which were that she would: 1) receive
a letter of reprimand; 2) participate in the Employee Assistance Program; 3) be transferred to another
school; and 4) agree that any additional acts of unlawful physical conduct would be grounds for
dismissal. On or about September 5, 2000, the Manager of Employee Relations for the district
issued the letter of reprimand for this incident.
CAROL A. HOSKINS
Administrative Complaint
Page 2 of 3
4. On or about February 15, 2001, the Respondent inappropriately disciplined R.L., a
male student in elementary school. She slapped or hit R.L. on his arm, slapped or hit him on his leg
and/or pushed him. This caused R.L. to cry. As a result of the incident, R.L.’s parents asked that
he be removed from the Respondent’s class for the remainder of the year. On or about March 15,
2001, the Respondent’s principal issued her a letter of reprimand for her inappropriate behavior.
5. On or about March 21, 2001, the Respondent inappropriately disciplined B.P., a
female student in elementary school. She forcibly grabbed B.P. by the arm, pulled her hands behind
her back and/or removed her from class by pulling her by the arm and/or by picking her up and
carrying her out. During this time, the Respondent was also yelling at B.P. As a result of this and
other incidents, B.P.’s parents requested that B.P. be removed from the Respondent’s class.
6. On or about March 23, 2001, the Respondent also failed to supervise B.P. and/or
failed to ensure that B.P. would be under the supervision of another. After removing B.P. from class,
the Respondent took her to the office and/or left her sitting unsupervised on a bench in the office.
. The Respondent failed to write a discipline referral for her as prescribed, which resulted in no plan
* for supervision or intervention being devised and which resulted in B.P.’s remaining unsupervised.
On or about May 4, 2001, the Manager of Employee Relations for the district placed the Respondent
on Relief of Duty status with pay. On or about May 23, 2001, he changed her Relief of Duty status
to “without pay.”
7. Between the beginning of the 2000-2001 school year and April 24, 2001, inclusive,
3 of the Respondent’s students (approximately 10%) had been reassigned to other classrooms at the
request of their parents and/or district level personnel.
8. On or about January 22, 2002, the Respondent entered into a Mediated Settlement
Agreement with the district, conditions of which were that the district would pay her $14,999.00 and
she would resign from the district effective January 22, 2002.
STATUTORY VIOLATIONS
COUNT 1: The allegations of misconduct set forth herein are in violation of Section
231.2615(1)(c), Florida Statutes, in that Respondent has been guilty of gross immorality or an aci
involving moral turpitude.
COUNT 2: The allegations of misconduct set forth herein are in violation of Section
231.2615(1)(f), Florida Statutes, in that Respondent, upon investigation, has been found guilty of
personal conduct which seriously reduces her effectiveness as an employee of the school board.
CAROL A. HOSKINS
Administrative Complaint
Page 3 of 3
COUNT 3: The allegations of misconduct set forth herein are in violation of Section
231.2615(1)(i), Florida Statutes, in that Respondent has violated the Principles of Professional
Conduct for the Education Profession in Florida prescribed by the State Board of Education.
RULE VIOLATIONS
COUNT 4: The allegations of misconduct set forth herein are in violation of Rule 6B-
1.001(2), Florida Administrative Code, in that Respondent has failed to have her primary
professional concern always be for the student and for the development of the student's potential and
has failed to seek to exercise the best judgment and integrity.
COUNT 5: The allegations of misconduct set forth herein are in violation of Rule 6B-
1.001(3), Florida Administrative Code, in the Respondent has failed to be aware of the importance
of maintaining the respect and confidence of her colleagues, of students, of parents and of other
members of the community and that Respondent has failed to achieve and sustain the highest degree
. of ethical conduct.
COUNT 6: The allegations of misconduct set forth herein are in violation of Rule 6B-
1,006(3)(a), Florida Administrative Code, in that Respondent has failed to make reasonable effort
to protect the student from conditions harmful to leaning and/or to the student’s mental health
and/or physical and/or safety.
COUNT 7: The allegations of misconduct set forth herein 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.
WHEREFORE, the Petitioner recommends that the Education Practices Commission
impose an appropriate penalty pursuant to the authority provided in Sections 231.262(7) and
231.2615(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 exceed
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.
EXECUTED on this_ 2 7_ day of. Sept oR as) ber , 2002.
Charlie Crist, as
Commissioner of Education,
State of Florida
Docket for Case No: 03-000561PL
Issue Date |
Proceedings |
Jun. 30, 2003 |
Subpoena ad Testificandum (16), E. Smith, E. Tan, D. Shearer, G. Allen, C. Russ, D. Hamm, A. Storms, B. Dodrill, D. Schmidt, S. Bagarella, S. Poteat, C. Upson, Mrs. R. Lawrence, R. Lawrence (2), S. Smith filed.
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Jun. 30, 2003 |
Return of Service filed. |
Jun. 30, 2003 |
Affidavit of Service (15) filed. |
Jun. 30, 2003 |
Notice of Filing, Affidavits filed.
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Jun. 23, 2003 |
Subpoena ad Testificandum (11), G. Alexander, D. Smith, S. Bagarella, J. Schennum, S. Davis, S. LaGarde, Dr. J. Keeley, J. Ashburn, J. Betsinger, S. Poteat filed.
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Jun. 23, 2003 |
Affidavit of Service (11) filed. |
Jun. 23, 2003 |
Notice of Filing (Affidavits) filed.
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Jun. 16, 2003 |
Order Closing File. CASE CLOSED.
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Jun. 16, 2003 |
Notice of Settlement (filed by K. Holbrook via facsimile).
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Jun. 13, 2003 |
Order on Motions for Protective Orders. (Respondent`s motion for protective order filed May 23, 2003, is denied, Petitioner`s emergency order for protective order filed on May 28, 2003 is denied; Petitioner`s renewed emergency motion for protective order filed on June 9, 2003, is denied)
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Jun. 11, 2003 |
Letter to Judge Kirkland from M. Rodriguez requesting subpoenas (filed via facsimile).
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Jun. 10, 2003 |
Joint Pre-Hearing Stipulation (filed via facsimile).
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Jun. 09, 2003 |
Renewed Emergency Motion for Protective Order (filed by Petitioner via facsimile).
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Jun. 06, 2003 |
Notice of Cancellation of Depositions, J. Betsinger, S. Poteat, S. Bagarella, D. Smith, S. LaGarde, Dr. J. Keeley, S. Smith, S. Davis, J. Ashburn, J. Schennum, C.D. (minor) (filed via facsimile).
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Jun. 03, 2003 |
Respondent`s Witness List (filed via facsimile).
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May 29, 2003 |
Emergency Motion for Protective Order (filed by Petitioner via facsimile).
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May 28, 2003 |
Response to Respondent`s Motion for Protective Order (filed by Petitioner via facsimile).
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May 23, 2003 |
Motion for Protective Order (filed by Respondent via facsimile).
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May 22, 2003 |
Letter to Judge Kirkland from M. Rodriguez requesting subpoenas (filed via facsimile).
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May 21, 2003 |
Notice of Taking Depositions, J. Betsinger, S. Poteat, S. Bagarella, D. Smith, S. LaGarde, Dr. J. Keeley, S. Smith, S. Davis, J. Ashburn, J. Schennum, C.D. (filed via facsimile).
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May 19, 2003 |
Petitioner`s Notice of Serving Answers to Respondent`s First Set of Interrogatories (filed via facsimile).
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May 16, 2003 |
Notice of Taking Deposition Duces Tecum, Records Custodian Seminole County School Board filed.
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May 16, 2003 |
Subpoena ad Testificandum (17), Records Custodian Seminole County School Board, D. Shearer, E. Newton, R. Lawrence, D. Ping, R. Lawrence, A. Storms, D. Hamm (Moss), G. Allen, C. Upson, D. Schmidt, B. Dodrill, C. Laroe, E. Smith, R. Blocker, G. Alexander, C. Russ filed.
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May 16, 2003 |
Subpoena Duces Tecum (2), Records Custodian Seminole County School Board, Records Custodian Osceola County School Board filed.
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May 16, 2003 |
Affidavit of Service (21) filed. |
May 16, 2003 |
Notice of Filing filed by Petitioner.
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Apr. 23, 2003 |
Order on Pending Motions issued. (Petitioner`s motion to exclude evidence at final hearing is denied, Respondent`s motion for protective order is denied, Respondent`s motion to compel discovery is granted in part and denied in part, the motion to compel the request to produce is denied)
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Apr. 22, 2003 |
Order Granting Continuance and Re-scheduling Hearing issued (hearing set for June 17 through 20, 2003; 9:00 a.m.; Orlando, FL).
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Apr. 21, 2003 |
Motion for Protective Order (filed by Respondent via facsimile).
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Apr. 18, 2003 |
Notice of Cancellation of Deposition (filed by Petitioner via facsimile).
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Apr. 18, 2003 |
Petitioner`s Amended Pre-Hearing Stipulation (filed via facsimile).
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Apr. 18, 2003 |
Motion to Compel Discovery filed by Respondent.
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Apr. 16, 2003 |
Respondent`s Answers to Petitioner`s Request for Admissions (filed via facsimile).
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Apr. 16, 2003 |
Subpoena Duces Tecum (2), Records Custodian Osceola County School Board, Seminole County School Board filed via facsimile.
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Apr. 16, 2003 |
Notice of Taking Deposition Duces Tecum (2), Records Custodian Osceola County School Board, Records Custodian Seminole County School Board (filed by Petitioner via facsimile).
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Apr. 16, 2003 |
Motion for Continuance of Hearing and Enlargment of Time to File Parties Pre-Hearing Statement (filed by Respondent via facsimile).
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Apr. 16, 2003 |
Petitioner`s Prehearing Stipulation (filed via facsimile).
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Apr. 16, 2003 |
Motion to Exclude Evidence at Final Hearing (filed by Petitioner via facsimile).
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Apr. 09, 2003 |
Subpoena Duces Tecum, Records Custodian Orange County School Board filed via facsimile.
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Apr. 09, 2003 |
Affidavit of Service (filed via facsimile). |
Apr. 09, 2003 |
Notice of Filing (filed by Petitioner via facsimile).
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Apr. 08, 2003 |
Letter to Judge Kirkland from M. Rodriguez requesting subpoenas (filed via facsimile).
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Apr. 07, 2003 |
Second Amended Notice of Taking Deposition, C. Hoskins (filed by Petitioner via facsimile).
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Apr. 02, 2003 |
Petitioner`s Notice of Serving Answers to Respondent`s First Set of Interrogatories (filed via facsimile).
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Apr. 02, 2003 |
Response to Respondent`s First Request for Production of Documents (filed by Petitioner via facsimile).
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Mar. 28, 2003 |
Amended Notice of Taking Deposition, C. Hoskins (filed via facsimile).
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Mar. 27, 2003 |
Notice of Taking Deposition, C. Hoskins (filed by Petitioner via facsimile).
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Mar. 27, 2003 |
Subpoena ad Testificandum, J. Teune filed via facsimile.
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Mar. 27, 2003 |
Notice of Taking Video Deposition, J. Teune (filed by Petitioner via facsimile).
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Mar. 26, 2003 |
Subpoena Duces Tecum, Records Custodian Orange County School Board filed via facsimile.
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Mar. 26, 2003 |
Notice of Taking Deposition Duces Tecum, Records Custodian Orange County School Board (filed by Petitioner via facsimile).
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Mar. 12, 2003 |
Order Granting Petitioner`s Motion to Amend the Administrative Complaint issued.
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Mar. 05, 2003 |
Subpoena Duces Tecum, Orange County School Board Records Custodian filed via facsimile.
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Mar. 05, 2003 |
Notice of Production from Non-Party (filed by M. Barber via facsimile).
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Mar. 04, 2003 |
Notice of Hearing issued (hearing set for April 23 and 24, 2003; 9:00 a.m.; Orlando, FL).
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Mar. 04, 2003 |
Order of Pre-hearing Instructions issued.
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Feb. 26, 2003 |
Notice of Appearance (filed by M. Barber via facsimile).
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Feb. 26, 2003 |
Joint Response to Initial Order (filed via facsimile).
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Feb. 26, 2003 |
First Request for Production of Documents (filed by Petitioner via facsimile).
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Feb. 26, 2003 |
Petitioner`s Request for Admissions (filed via facsimile).
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Feb. 26, 2003 |
Notice of Service (filed by Petitioner via facsimile).
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Feb. 26, 2003 |
Motion to Amend Administrative Complaint (filed by Petitioner via facsimile).
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Feb. 19, 2003 |
Initial Order issued.
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Feb. 18, 2003 |
Election of Rights filed.
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Feb. 18, 2003 |
Administrative Complaint filed.
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Feb. 18, 2003 |
Agency referral filed.
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