STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, Vs. CASE NO. 123-1981 MARY PATRICIA MALONEY, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against MARY PATRICIA MALONEY. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educator's certificate pursuant to Sections 1012.315, 012.795, 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: JURISDICTION L. The Respondent holds Florida Educator’s Certificate 861336, covering the areas of Mathematics, Middle Grades Integrated Curriculum and Social Science, which is valid through June 30, 2016, 2. At all times pertinent hereto, the Respondent was employed as a Mathematics Teacher at Palm Springs Middle School in the Palm Beach County School District. MATERIAL ALLEGATIONS 4 3. On or about May 24, 2009, in Palm Beach County, Florida, Respondent operated a motor vehicle while under the influence of alcohol. Respondent was arrested and charged with Driving Under the Influence. On or about October 29, 2009, in the County Court of the Fifteenth Judicial Circuit, in and for Palm Beach County, Florida, Respondent was adjudicated guilty of Driving Under the Influence. MARY PATRICIA MALONEY Administrative Complaint Page 2 of 3 4, On or about January 13, 2013, in Palm Beach County, Florida, Respondent was imvolved in a traffic crash while operating a motor vehicle while she was under the influence of alcohol, Respondent’s vehicle struck another vehicle when Respondent failed to stop at a red- light traffic signal. Respondent left the scene of the crash. Respondent refused to cooperate with law enforcement officers, in that Respondent refused to answer questions, refused sobriety tests and resisted being handcuffed. Respondent was arrested and charged with Driving Under the Influence (Refusal), Crash/Leaving Scene With Damage, Resisting Officer Without Violence, and Driving While License Suspended With Knowledge. Subsequent to arrest, Respondent attempted to bribe a law enforcement officer, in that she stated, “How much do I need to pay you io just let me go? Don’t you understand J am a school teacher? If you want I can suck your cock and let you play with my tits,” or words to that effect. As a result, Respondent was charged with two counts of Bribery of a Public Servant. 5. On or about February 1, 2013, an Information was filed charging Respondent with Count 1: Driving Under the Influence, Count 2: Leaving Scene of Crash Involving Damage, and Count 3: Resist Officer Without Violence. 6. On or about July 22, 2013, in the County Count of the Fifteenth Judicial Circuit, in and for Palm Beach County, Florida, Respondent pled guilty to, and was adjudicated guilty of, Counts 1, 2 and 3. 7. On or about December 6, 2013, as a result of the conduct alleged in Paragraphs 4 and 6 of this Administrative Complaint, the Palm Beach County School District notified Respondent of its intent to terminate Respondent’s employment. On or about January 24, 2014, Respondent's employment was terminated. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: 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. 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 effectiveness as an employee of the school board. (SIGNATURE ON FOLLOWING PAGE) MARY PATRICIA MALONEY 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 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 9% day of __ March , 2015, Abou—boves PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 15-007092PL