STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, VS. CASE NO. 123-0580 AUDREY JEAN SHULER, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against AUDREY JEAN SHULER, 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 6A-10.081, 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: 1. The Respondent holds Florida Educator’s Certificate 344926, covering the areas of Elementary Education, Mentally Handicapped and Specific Learning Disabilities, which is valid through June 30, 2017. 2. At al] times pertinent hereto, the Respondent was employed as an Exceptional Student Education Liaison in the Exceptional Student Education Department in the Santa Rosa County School District. MATERIAL ALLEGATIONS 3, During the summer of 2012 the Respondent submitted twenty-five Individual Edueation Plans to Central School in the Santa Rosa County School District. The Respondent forged the signatures of one or more educators on each of these Individual Education Plans, 4, On or about August 27, 2012, the Respondent resigned from her position of employment with the Santa Rosa County School District effective September 1, 2012. AUDREY JEAN SHULER Adininistrative Complaint Page 2 of 3 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)(g), 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)(), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession prescribed by State Board of Education rules. RULE VIOLATIONS COUNT 4: The allegations of misconduct set forth herein are in. violation of Rule 6A- 10.081(3) (8), Florida Administrative Code, in that Respondent has intentionally violated or denied a student’s legal rights. COUNT 5: — The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(5)(a), Florida Administrative Code, in that Respondent has failed to maintain honesty in all professional dealings. (SIGNATURE ON FOLLOWING PAGE) AUDREY JEAN SHULER 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 of a combination of the following: issuing the Respondent a written re primand; 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. EXECUTED on this | day of Mecembbar 2013. PAM STEWART, as _ Commissioner of Education State of Florida

Docket for Case No: 14-001759PL