STATE OF FLORIDA 2008 EDUCATION PRACTICES COMMISSION APR ~q 4 053 O€IT2ZU PL ABRIYISION of JOHN L. WINN, as nels TRATI Ve Commissioner of Education, , ARINGS Petitioner, . vs. CASE NO, 045-3273-F AMANDA F, LUCAS, Respondent. / AD TVE COMP’ Petitioner, John L. Winn, as Commissioner of Education, files this Administrative Complaint against AMANDA F. LUCAS. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educator’s certificatc pursuant to Sections 1012.795 and 1012.796, 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 1012.795(1) and 1012.796(7), Florida Statutes. The Petitioner alleges: JURISDICTION 1, The Respondent holds Florida Educator’s Certificate 592447, covering the areas of English, English to Speakers of Other Languages (ESOL), Speech and Middle Grades, which is valid through June 30, 2007. 2. At all times pertinent hereto, the Respondent was employed as a Language Arts Teacher at Darnell Cookman Middle School in the Duval County School District. MATERIAL ALLEGATIONS 3. Between June 1, 2004 and March 1, 2005, Respondent provided alcohol and cigarettes to minors in her home. On or about March 4, 2005, Respondent was issued a notice to appear with regard to the offenses of: Count 1, Permit person under 21 to consume alcohol on premises and count 2, Contributing to Delinquency of Child, On or about April 25, 2005, Respondent resigned from her teaching position with the district after being suspended without pay. On or about May 25, 2005, Respondent was charged by information with: Count 1, Sale of Alcohol AMANDA F. LUCAS Administrative Complaint Page 2 of 3 to a Minor; Counts 2 through 5, Contributing to the Delinquency of a Minor; Counts 6 through 9, Providing Alcoholic Beverages to a Person Under the Age of 21. On or about May 22, 2006, Respondent pled nolo contendere to Count 2 and the court withheld adjudication, Count t was dropped and all other counts were nolle prossed. STATUTE VIOLATIONS COUNT i: The Respondent is in violation of Section 1012.795(1)(c), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude. COUNT 2: — The Respondent is in violation of Section 1012.795(1)(f), Florida Statutes, in that Respondent has been found guilty of personal conduct which seriously reduces her effectiveness as an employee of the school board. COUNT3: The Respondent is in violation of Section 1012.795(1)(i), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession prescribed by State Board of Education rules. RULE LATIONS COUNT 4: 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 cffort to protect the student from conditions harmful to learning and/or to the student’s mental health and/or physical health and/or safety. (SIGNATURE ON FOLLOWING PAGE) AMANDA F. LUCAS Administrative Complaint Page 3 of 3 WHEREFORE, based on the reasons set forth herein and in accordance with the Explanation of Rights and Election of Rights forms attached to and made a part of this Administrative Complaint, Petitioner respectfully recommends that the Education Practices Commission impose an appropriate sanction against the Respondent’s educator’s certificate pursuant to the authority provided in Sections 1012.795(1) and 1012.796(7), Florida Statutes. The sanctions imposed by the Education Practices Commission may include, but are not limited to, any one or a combination of the following: issuing the Respondent a written reprimand; placing the Respondent on probation for any period of time; restricting the Respondent’s authorized scope of practice; assessing the Respondent an administrative fine; directing the Respondent to enroll in the Recovery Network Program; suspending the Respondent’s educator’s certificate for a period of time not to exceed five years; revoking the Respondent’s educator’s certificate for a periad of time up to 10 years or permanently; or barring the Respondent from reapplying for an educator’s certificate for a period of time up to 10 years or permanently. EXECUTED on this Zl» dayof October —_, 2006. Jil J L. WINN, as Commissioner of Education State of Florida

Docket for Case No: 08-001722PL