STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 167-2735 KARYL ST. PETER, Respondent. f ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against KARYL ST. PETER. 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 914640, covering the areas of Elementary Education and Exceptional Student Education, which is valid through June 30, 2019. 2. At all times pertinent hereto, the Respondent was employed as a Varying Exceptionalities Teacher at Zora Neale Hurston Elementary School in the Hillsborough County School District. MATERIAL ALLEGATIONS 3. On or about September 17, 2013, prior to participating in an English for Speakers of Other Languages (ESOL) endorsement course (course) offered by the Hillsborough County School District, Respondent acknowledged an Academic Integrity Statement. By acknowledging the Academic Integrity Statement, Respondent agreed that while satisfying the requirements of the course, she would ensure that she would not plagiarize or copy the work of another participant and submit the work as her own, Despite acknowledging the Academic Integrity Statement, on or about November 24, 2013, Respondent obtained the work of another teacher KARYL ST. PETER Administrative Complaint Page 2 of 2 who previously completed the assignments, plagiarized the other teachers’ work, and submitted the work as her own for course credit. 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. ‘ 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 A day of, j Wi , 2017. PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 17-005525PL