STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, Petitioner, CASE NO.: 2014-07618 Vv. STANTON TUCKER COOPER, D.C., Respondent. / ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, Department of Health, by and through its undersigned counsel and files this Administrative Complaint before the Board of Chiropractic Medicine against the Respondent, Stanton Tucker Cooper, D.C., and in support thereof alleges: 1. Petitioner is the state department charged with regulating the practice of chiropractic medicine pursuant to Chapters 20, 456, and 460, Florida Statutes (2013-2014). 2. At all times material to this Complaint, Respondent was a chiropractic physician in the State of Florida, having been issued license number CH 3976. 3. On or about May 17, 2013, Respondent executed a Professionals Resource Network (“PRN”) monitoring contract. DOH v. Stanton Tucker Cooper, D.C. DOH Case Number 2014-07618 1 4. PRN is a Department-contracted consultant for matters dealing with impaired healthcare practitioners. 5. On or about December 30, 2013, Respondent provided a specimen for a PRN-facilitated drug screen, which was positive for alcohol use. 6. On or about January 14, 2014, Respondent underwent a PRN- facilitated mental and physical evaluation with S.S., M.D. 7. On or about January 29, 2014, Respondent requested. a second opinion PRN-evaluation. 8. | Respondent failed to undergo a second opinion PRN-evaluation. 9. Onor about May 15, 2014, PRN terminated Respondent’s monitoring contract. 10. On or about October 2, 2014, Respondent underwent a Department- compelled mental and physical evaluation with T.J., M.D. 1i. Dr. T.J. diagnosed Respondent with opiate dependence/possible addiction and borderline personality disorder. 12. Dr. T.J. opined that Respondent is not safe to practice as a chiropractic physician with reasonable skill and safety to patients. COUNT I 13. Petitioner realleges and incorporates by reference paragraphs one (1) through twelve (12) as if fully set forth herein. DOH v. Stanton Tucker Cooper, D.C. DOH Case Number 2014-07618 2 14. Section 460.413(1)(q), Florida Statutes (2013-2014), subjects a chiropractic physician to discipline, including restriction, for “[b]eing unable to practice chiropractic medicine with reasonable skill and safety to patients by reason of illness or use of alcohol, drugs, narcotics, chemicals, or any other type of material or as a result of any mental or physical condition.” 15. Respondent violated Section 460.413(1)(q), Florida Statutes (2013- 2014) by being unable to practice chiropractic medicine with reasonable skill and safety to patients due to one or more of the following: i. Opiate dependence/possible addiction; and/or ii. borderline personality disorder. 16. Based on the foregoing, Respondent violated Section 460.413(1)(q), Florida Statutes (2013-2014) by being unable to practice chiropractic medicine with reasonable skill and safety to patients by reason of illness or use of alcohol, drugs, narcotics, chemicals, or any other type of material or as a result of any mental or physical condition. COUNT II 17. Petitioner realleges and incorporates by reference paragraphs one (1) through twelve (12) as if fully set forth herein. 18. Section 460.413(1)(ff) Florida Statutes (2013-2014), subjects a licensee to discipline, including restriction, for violating any provision of DOH v, Stanton Tucker Cooper, D.C, DOH Case Number 2014-07618 3 chapter 460 or chapter 456, Florida Statutes, or any rules adopted pursuant thereto. 19. Section 456.072(1)(hh), Florida Statutes (2013-2014), subjects a licensee to discipline for being terminated from a treatment program for impaired practitioners, for failure to comply, without good cause, with the terms of the monitoring or treatment contract entered into by the licensee, or for not successfully completing any drug treatment or alcohol treatment program. 20. Respondent violated 460.413(1)(ff), Florida Statutes (2013-2014), by violating Section 456.072(1)(hh), Florida Statutes (2013-2014), by being terminated from PRN due to Respondent failing to comply with the terms of his PRN monitoring contract without good cause. 21, Based on the foregoing, Respondent violated Section 460.413(1)(ff), Florida Statutes (2013-2014), by violating Section 456.072(1)(hh), Florida Statutes (2013-2013), by being terminated from a treatment program for impaired practitioners, for failure to comply, without good cause, with the terms of the monitoring or treatment contract entered into by the licensee, or for not successfully completing any drug treatment or alcohol treatment program. DOH v. Stanton Tucker Cooper, D.C. DOH Case Number 2014-07618 WHEREFORE, Petitioner respectfully requests that the Board of Chiropractic Medicine 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 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 las day of Novemkey , 2014, John H. Armstrong, MD, FACS State Surgeon General and Secretary of Health ON” SECS onda arine Gialella Assistant General Counsel DOH Prosecution Services Unit FILED 4052 Bald Cypress Way, Bin C-65 DEPARTMENT OF HEALTH Tallahassee, FL 32399-3265 DEPUT Florida Bar Number 0091101 Sand DATE NOV1 3 208 Phone (850) 245-4444 x 8199 Fax (850) 245-4662 Karine.Gialella@fihealth.gov PCP: November 13, 2014 PCP Members: Christopher Fox, D.C. & Danita Heagy, D.C. DOH v. Stanton Tucker Cooper, D.C.; DOH Case No. 2014-07618 DOH vy. Stanton Tucker Cooper, D.C. DOH Case Number 2014-07618 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 any other discipline imposed. DOH v., Stanton Tucker Cooper, D.C. DOH Case Number 2014-07618

Docket for Case No: 16-003258PL