FILED

Department of Bu-slo and Professional Reiulation

Deputy Agency Clerk

CLERK Evette Lawson-Proctor

Date 5/10/2011

File#

STATE OF ltt1JRI · t 'l

DEPARTMENT OF BUSINESS ANO PR.0FESS'l0NAL REGULATION

DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, BOARD OF ARCHITECTURE

AND INTERIOR DESIGN,

Petitioner,

20!l JUL I 5 A 11: I2

vs. CASE NO.: 2009-058257

HUGHS. WRIGHT,

Respondent.

;/

ADMINISTRATIVE COMPLAINT

Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION,

("Petitioner"), files this Administtative Complaint before the Board of Architecture and Interior Design against HUGH S. WRIGHT, ("Respondent"), and says:

l. Petitioner is the state agency charged with regulating the practice of architecture and interior design pursuant to Section 20.165, Florida Statutes, and Chapters 455 and 481, Florida Statutes.

1. The Department of Business and Professional Regulation has jurisdiction over the unlicensed practice of architecture pursuant to Section 455.228(1), and Section 48l.223(l)(a), Florida Statutes.

2. Respondent's last known address is 420 South Alabama A venue, Deland, FL

   
   

   32724.

   
   

3. At all times material hereto, Respondent was not duly registered or certified to engage in the practice of architecture pursuant to Chapter 481, Florida Statutes.

   
   

4. Respondent ,vas previously a licensed architect 111 the State or Florida, having been issued license number AR 4605.

5. As of March I, 1989, Respondent's license was placed in a delinquent status for failing to renew.

6. As of March I, 1991, Respondent's license was placed in a null and void status for failing to renew.

7. On or about July 18, 2009, Respondent signed and scaled a set of drawings using his null and void license.

8. Respondent held himself out as an architect to the building dcpa11mcnt.

l 0. Respondent is no longer a licensed architect in the State of Florida and therefore cannot use his null and void license numher, use the title architect, or o ffcr architectural services.

COUNT I

1. Petitioner hereby realleges and incorporates paragraphs one ( l) through ten (10) as if fully set forth herein.

2. Section 481.223( I )(a), Florida Statutes, states that a person may not knowingly "practice architecture unless the person is an architec1 or a registered architect."

3. Based upon the foregoing, Respondent has violated Section 481.223(1)(a), Florida Statutes, by practicing architecture when he was not the holder of a valid license by offering to provide architectural services.

   COUNT II

   
   

4. Petitioner hereby realleges and incoq)oratcs paragraphs one (I) through ten (10) as if fully set forth herein.

5. Section 481.223(1)(c), Florida Statutes, states that a person may not knowingly "use

   
   

   
   

   the name or title 'architect' or 'registered architect' or words to that effect, when the person is not then the holder of a valid license."

6. Based upon the foregoing, the Respondent has violated Section 481.223( l )(c), Florida Statutes, by using the name or title "architect", when he was not the holder of a valid license.

   COUNT III

   
   

7. Petitioner l1ereby reallegcs and incorporates paragraphs one ( l) through ten ( t 0) as if fully set forth herein.

8. Section 481.223( I )(f), Florida Statutes, prohibits a person from using or attempting to use an architect license that has been suspended, revoked, or placed on inactive or delinquent status.

9. Based upon the foregoing, the Respondent has violated Section 481.223( l )(f),

Florida Statutes, by attempting to use his architect license while it was in a null and void status.

WHEREFORE, Petitioner respectfully requests the Board enter an Order imposing an administrative fine not to exceed $5,000 per count, assess costs associated with investigation and prosecution, impose any or all penalties delineated within Section 455.227(2), Florida Statutes, and/or any other relief that the Board is authorized to impose pursuant to Chapters 48 I and 455,

Florida Statutes, and/or the rules promulgated thereunder.

st \o\

Signed this S-

day of ---r17

.....,,1 , 20 I I.

PCP: May 2, 2011

Rodriguez Wi1tz.

Gustafson

=; :s Y--

DA YID K. MINACCI

Smith, Thompson, Shaw, Minacci & Colon, P.A.

3520 Thomasville Road, Fourth Floor Tallahassee, Florida 32309

FL Bar No. 0056774 Ph: (850) 402-1570

Fax: (850)241-0161

Docket for Case No: 11-003429PL