STATE OF FLORIDA EDUCATION PRACTICES COMMISSION DR. ERIC J. SMITH, as Commissioner of Education, Petitioner, vs. CASE NO. 078-3685 ADRIENNE F, LAFLAMME, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Dr. Eric J. Smith, as Commissioner of Education, files this Administrative Complaint against ADRIENNE F. LAFLAMME. The Petitioner seeks the appropriate disciplinary _ sanction of the Respondent’s educator’s certificate pursuant to Sections 1012.315, 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 334733, covering the areas of Health Education, Physical Education, and Adaptive Physical Education, which is valid through June 30, 2012. 2. Atall times pertinent hereto, the Respondent was employed as a Dropout Prevention Teacher at Juvenile Detention Center in the Brevard County School District. MATERIAL ALLEGATIONS 3. Beginning on or about May 16, 2008, in Brevard County, Florida, Respondent engaged in sexual intercourse and oral sex with seventeen-year-old male M.Z. on approximately fifteen occasions. Respondent allowed M.Z. to use her vehicle, and subsequently reported to police that her vehicle had been stolen. In a controlled telephone call with M.Z., Respondent admitted that she had sexual intercourse with M.Z., simultaneously engaged in sexual acts with M.Z. and fourteen- year-old male R.W., and lied to police about her vehicle being stolen. Filed October 18, 2011 10:48 AM Division of Administrative Hearings ADRIENNE F. LAFLAMME Administrative Complaint Page 2 of 3 4. On or about June 25, 2008, Respondent was arrested and charged with the following: . Counts 1-20: Unlawful Sexual Activity with a Minor; * Count 21: Lewd or Lascivious Conduct; . Count 22: Lewd or Lascivious Exhibition; ° Count 23: Lewd or Lascivious Molestation; ° Count 24: Lewd or Lascivious Battery; . Count 25: Delivery of a Controlled Substance to a Minor; ° Count 26: Contributing to the Delinquency of a Minor; . Count 27: Filing False Police Report 5. On or about February 27, 2011, Respondent pled guilty to, and the court adjudicated her guilty of counts 1 through 3, Unlawful Sexual Activity with a Minor, and count 27, Filing False Police Report. Counts 4 through 26 were nolle prossed. The convictions for Unlawful Sexual Activity with a Minor are violations of Florida Statutes, 794.05(1), and disqualify the Respondent from holding an educator’s certificate pursuant to Section 1012.795, Florida Statutes. 6. Pursuant to Section 1012.795(2), Florida Statutes, the plea of guilty or the decision of guilty by a court is prima facie proof of grounds for the revocation or other sanction of a teaching certificate. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1)(d), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude as defined by rule of the State Board of Education. COUNT 2: The Respondent is in violation of Section 1012.795(1)(f), Florida Statutes, in that Respondent has been convicted or found guilty of, or entered a plea of guilty to, regardless of adjudication of guilt, a misdemeanor, felony, or any other criminal charge, other than a minor traffic violation. COUNT3: The Respondent is in violation of Section 1012.795(1)(j), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession prescribed by State Board of Education rules. COUNT 4: The Respondent is subject to Section 1012.795(1)(n), Florida Statutes, in that Respondent has been disqualified from educator certification under 1012.315, Florida Statutes. ADRIENNE F, LAFLAMME Administrative Complaint Page 3 of 3 RULE VIOLATIONS COUNT 5: 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 learning and/or to the student’s mental health and/or physical health and/or safety. 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 exploited a relationship with a student for personal gain or advantage. 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 writien 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 period of time up to 10 years or permanently; determining the Respondent to be ineligible for certification; or barring the Respondent from reapplying for an educator’s certificate for a period of time up to 10 years or permanently, idly A EXECUTED on this i \*b dayof__{ Vex 2011, DR. ERIC J SMITH, as Commissioner of Education State of Florida

Docket for Case No: 11-005342PL