STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 156-3131 AISHA BROWN, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against AISHA BROWN. 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 922435, covering the area of English, which is valid through June 30, 2021. MATERIAL ALLEGATIONS 2 On or about June 22, 2014, Respondent stole approximately $250 worth of merchandise from a department store. As a result of the aforementioned conduct, Respondent was arrested and charged with Petit Theft. Thereafter, she pled nolo contendere; on or about September 3, 2014, Respondent entered into a Misdemeanor Diversion Program. 3. On or about May 8, 2015, Respondent stole approximately $650 worth of merchandise from a department store. As a result of the aforementioned conduct, Respondent was arrested and charged with Grand Theft thereafter amended to Petit Theft. Thereafter, she pled no contest; on or about March 18, 2016, adjudication was withheld. AISHA BROWN Administrative Complaint Page 2 of 3 4. On or about June 4, 2015, Respondent stole merchandise from a department store. As a result of the aforementioned conduct, Respondent was arrested and charged with Petit Theft. She pled not guilty to the aforementioned charge; on or about December 22, 2015, adjudication was withheld. 5. On or about April 11, 2016, Respondent submitted an application to renew her educator’s certificate. Said application provides the following: Florida Law requires you to provide a YES or NO answer to the questions within the Legal Disclosure section of your application, even if previously submitted. If you answered YES to any question in the Legal Disclosure section on the application form, you must provide detailed[,] complete information for each affirmative response within the corresponding section in this Legal Disclosure Supplement. 6. Respondent answered “Yes,” to following question: “Have you ever entered into a pretrial diversion program or deferred. prosecution program related to a criminal offense?” Respondent, however, failed to disclose that on March 18, 2016, adjudication was withheld on her May 8, 2015 Petit Theft arrest. This was in conflict with legal disclosure affidavit that Respondent signed at the end said application, which provides: “I. . . do hereby affirm that all information provided in this Legal Disclosure Section and supplement to my application for a Florida Educator’s Certificate is true, accurate{,] and complete.” The Petitioner charges: STATUTE VIOLATIONS COUNT 1: 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 2: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(2)(c)1, Florida Administrative Code, in that Respondent has failed to maintain honesty in all professional dealings. COUNT 3: The Respondent is in violation of Rule 6A-10.081(2)(c)8, Florida Administrative Code, in that Respondent has submitted fraudulent information on a document in connection with professional activities. (SIGNATURE ON FOLLOWING PAGE) AISHA BROWN 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 LOA day ot Mtb _, 2016. PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 17-004993PL