STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vB. CASE NO. 156-3462 LETTY JO RICHARDSON, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against LETTY JO RICHARDSON. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educator’s certificate pursuant to sections 1012.3 15, 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 Educater’s Certificate 781650, covering the areas of English and School Principal, which is valid through June 30, 2020. 2. At all times pertinent hereto, the Respondent was cmployed as a Principal at Performance Based Preparatory Academy in the St. Lucie County School District. MATERIAL ALLEGATIONS 3, During the 2015-2016 school year, Respondent facilitated the submission of a fraudulent student expulsion letter to the St. Lucie County School District istrict). The letter falsely stated that student M.W. had previously been expelled from all schools in the District and included a forged signature. Respondent submitted the letter for purposes of delaying the enrollment of M.W. at Respondent’s school. The delay resulted in a loss of funds to the school. 4, In or around June of 2016, Respondent responded to an inquiry by Indian River County School District for a reference check regarding Respondent’s former employee, M.D., LETTY JO RICHARDSON Administrative Complaint Page 2 of 3 with fraudulent information. Respondent failed to disclose that M.D. had been under investigation by the St, Lucie County School District despite having full knowledge that an investigation occurred while M.D. was under Respondent’s supervision. Respondent answered “no” to the question: “To your knowledge, has this individual [M.D.] ever received an unsatisfactory evaluation, been placed on probation, been the subject of an investigation, been disciplined, been non-renewed, or placed on a plan for improvement?” The Petitioner charges: STATUTE VIOLATIONS COUNT 1: 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 2: The Respondent is in violation of section 1012.795(1)(j), 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 3: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(2\(a)1, 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 physical health and/or safety. COUNT 4: 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. COUNTS: 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) LETTY JO RICHARDSON 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. mxecure on this LUA aay ot Jule ____, 2017, /) f; / fh / hin Perey PAM STEWART, as_ ; Commissioner of Education State of Florida

Docket for Case No: 17-005528PL