STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, V. CASE NO. 2010-21087 JOAN RENE HAMPTON, R.N., RESPONDENT. / ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, Department of Health, by and through its undersigned counsel, and files this Administrative Complaint before the Board of Nursing against Respondent, Joan Rene Hampton, R.N., and in support thereof alleges: 1. Petitioner is the state department charged with regulating the practice of nursing pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter 464, Florida Statutes. 2. At all times material to this Administrative Compiaint, Respondent was a licensed registered nurse (R.N.) within the state of Florida, having been issued license number RN 9254192, Filed June 14, 2012 2:52 PM Division of Administrative Hearings 3. Respondent's address of record is 2475 Robb Drive Apt. 1124, Reno, NV 89523, 4. The Texas Board of Nursing is the licensing authority of the practice of nursing in the state of Texas. 5. Respondent's Texas nursing certificate is number 714842, 6. On or about October 22, 2010, the Texas Board of Nursing entered an Opinion and Order of the Board against Respondent. 7. The Opinion and Order of the Board revoked Respondent's Texas nursing certificate number 714842. 8. Section 464.018(1)(b), Florida Statutes (2010), provides that having a license to practice nursing revoked, suspended, or otherwise acted against, including the denial of licensure, by the licensing authority of another state, territory, or country constitutes grounds for disciplinary action. 9. Respondent had a license to practice nursing revoked, suspended, or otherwise acted against by the licensing authority of another state, territory, or country by having her Texas nursing certificate revoked when the Texas Board of Nursing entered an Opinion and Order of the Board against Respondent on or about October 22, 2010. Department of Health v. Joan Rene Hampton, RN, Case Number 2010-21087 J\PSU\Nursing\Michael\ACs\Drafted ACs\ACs\Hampton, Joan.doc to 10. Based on the foregoing, Respondent violated Section 464.018(1)(b), Florida Statutes (2010), by having a license to practice nursing revoked, suspended, or otherwise acted against, including the denial of licensure, by the licensing authority of another state, territory, or country. Department of Health v, Joan Rene Hampton, R.N, 7 Case Number 2010-21087 2:\PSU\Nursing\Michael\ACs\ Drafted ACs\ACs\Hampton, Joan.doc WHEREFORE, the Petitioner respectfully requests that the Board of Nursing enter an order imposing one or more of the following penalties: permanent revocation or suspension of Respondent's license, restriction of practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, corrective action, refund of fees billed or collected, remedial education and/or any other relief that the Board deems appropriate. SIGNED this _) [1% day of _[|/o 201] . H. Frank Farmer, Jr., M.D., Ph.D. State Surgeon, General § tab Assistant General Counsel DEPARTMENT OF HEALTH DOH Prosecution Services Unit DEPUTY CLERK 4052 Bald Cypress Way, Bin C-65 Tallahassee, Florida 32399-3265 Florida Bar Number 0011265 pate: MAY 31 201 (850) 245 - 4640 Telephone (850) 245 - 4683 Facsimile /MGL pcp: MAY 26 201 PCP Members: Ader ne, ~ Heit Department of Health v. Joan Rene Hampton, R.N. 4 Case Number 2010-21087 J:\PSU\Nursing\Michael\ACs\Drafted ACs\ACs\Hampton, Joan.doc NOTICE OF RIGHTS Respondent has the right to request a hearing to be conducted in accordance with Section 120.569 and 120.57, Florida Statutes, to be represented by counsel or other qualified representative, to present evidence and argument, to call and cross-examine witnesses and to have subpoena and subpoena duces tecum issued on his or her behalf if a hearing is requested. NOTICE REGARDING ASSESSMENT OF COSTS Respondent is placed on notice that Petitioner has incurred costs related to the investigation and prosecution of this matter. Pursuant to Section 456.072(4), Florida Statutes, the Board shall assess costs related to the investigation and prosecution of a disciplinary matter, which may include attorney hours and costs, on the Respondent in addition to any other discipline imposed. Department of Health v. Joan Rene Hampton, R.N. 5 Case Number 2010-21087 J:\PSU\Nursing\Michael\ACs\Drafted ACs\ACs\Hampton, Joan.doc

Docket for Case No: 12-002076PL