STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 134-3124 LAURA VAUGHN SULLIVAN, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against LAURA VAUGHN SULLIVAN. 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: JURISDICTION 1. The Respondent holds Florida Educator’s Certificate 925659, covering the areas of English and English for Speakers of Other Languages (“ESOL”), which is valid through June 30, 2016. 2. At all times pertinent hereto, the Respondent was employed as an English Teacher at Hobbs Middle School in the Santa Rosa County School District. MATERIAL ALLEGATIONS 4 3. On or about April 18, 2014, Respondent illegally operated a motor vehicle under the influence of alcohol with a minor in the vehicle. As a result of the aforementioned conduct, Respondent was arrested for Driving Under the Influence with .15 Blood Alcohol or Breath Alcohol Level or Higher and Cruelty Toward Child that Could Result in Physical/Mental Injury. On May 5, 2014, Respondent was charged with Child Neglect—without Causing Great Bodily Harm, Permanent Disability, or Permanent Disfigurement and DUI with .15 Blood or Breath Alcohol Level or Higher. On November 17, 2014, Respondent pled nolo contendere to the LAURA VAUGHN SULLIVAN Administrative Complaint Page 2 of 3 aforementioned charges. On or about November 17, 2014, Respondent was adjudicated guilty of Driving Under the Influence with .15 Blood or Breath Aleoho! Level or Higher; however, the State Attorney's Office nolle prossed the Child Neglect without Causing Great Bodily Harm charge. 4, On or about October 3, 2014, Respondent was under the influence of alcohol on school property and during school hours. Respondent's supervisor smelled the odor of alcohol emanating from her person and also observed that her eyes were blood shot and she appeared lethargic. Based upon these observations, Respondent’s supervisor concluded that she had reasonable suspicion to test Respondent. Respondent thereafter submitted to a reasonable- suspicion test, On October 15, 2014, Respondent resigned in lieu of termination. 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 adjtidication of guilt; a niisderieanor, felony, or any other ovina 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. COUNT 3: The Respondent is in violation of section 1012.795(1)G), 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)(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 physica) health and/or safety. (SIGNATURE ON FOLLOWING PAGE) LAURA VAUGHN SULLIVAN 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 asc _. day of Pace woe’ , 2015, Commissioner of Education State of Florida

Docket for Case No: 16-000409PL