STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, V. CASE NO. 2016-13930 JESSICA LAUREN ROBINSON, R.N., RESPONDENT. ADMINISTRATIVE COMPLAINT Petitioner Department of Health files this Administrative Complaint before the Board of Nursing against Respondent Jessica Lauren Robinson, R.N., and in support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice of nursing pursuant. to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter 464, Florida Statutes. 2. At all times material to this Complaint, Respondent was licensed as a registered nurse within the state of Florida, having been issued license number RN 9263866. 3. Respondent's address of record is 13711 Clarence Dobbs Road, Glen Saint Mary, Florida 32040. 4. On or about March 8, 2016, Jeremy Mirabile, M.D., a physician specializing in addiction medicine, evaluated the Respondent. 5. Dr. Mirabile diagnosed the Respondent with moderate-to-severe opioid use disorder, moderate cocaine or stimulant use disorder, moderate alcohol use disorder, mild cannabis use disorder, mild sedative/hypnotic use disorder, and major depressive disorder. 6. Dr. Mirabile opined that the Respondent is not able to practice nursing with the reasonable skill and safety to patients. 7. Section 464.018(1)(j), Florida Statutes (2015), subjects a registered nurse to discipline for being unable to practice nursing with reasonable skill and safety to patients by reason of illness or use of alcohol, drugs, narcotics, or chemicals or any other type of material or as a result of any mental or physical condition. 8. Respondent violated Section 464.018(1)(j), Florida Statutes (2015), by being unable to practice nursing with reasonable skill and safety to patients due to her moderate-to-severe opioid use disorder, moderate cocaine or stimulant use disorder, moderate alcohol use disorder, mild cannabis use disorder, mild sedative/hypnotic use disorder, and/or major depressive disorder. DOH vs. Jessica Lauren Robinson, R.N. 2 Case No: 2016-13930 : 9. Based on the foregoing Respondent has violated Section 464.018(1)(j), Florida Statutes (2015), by being unable to practice nursing with reasonable skill and safety to patients by reason of illness or use of alcohol, drugs, narcotics, or chemicals or any other type of material or as a result of any mental or physical condition. WHEREFORE, Petitioner respectfully requests that the Board of Nursing 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 i day of Aus _, 2016. Celeste Philip, MD, MPH Surgeon General and Secretary c Rob F. Summers Assistant General Counsel DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, FL 32399-3265 Florida Bar Number 0099658 Phone (850) 245-4444 x 8150 Fax (850) 245-4662 Robert.Summers@flhealth.gov DOH vs. Jessica Lauren Robinson, R.N. Case No: 2016-13930 . RFS/cb PCP: August 9, 2016 PCP Members: Claydell Horne, PhD, RN (Panel Chair) Lori Desmond, MSN, RN, NE-BC FILED Department OF Health Deputy Cle DATE DOH vs. Jessica Lauren Robinson, R.N. Case No: 2016-13930 Angel Se CLERK yg a 120 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. A request or petition for an administrative hearing must be in writing and must be received by the Department within 21 days from the day Respondent received the Administrative Complaint, pursuant to Rule 28-106.111(2), Florida Administrative Code. If Respondent fails to request a hearing within 21 days of receipt of this Administrative Complaint, Respondent waives the right to request a hearing on the facts alleged in this Administrative Complaint pursuant to Rule 28-106.111(4), Florida Administrative Code. Any request for an administrative proceeding to challenge or contest the material facts or charges contained in the Administrative Complaint must conform to Rule 28-106.2015(5), Florida Administrative Code. Mediation under Section 120.573, Florida Statutes, is not available to resolve this Administrative Complaint. 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 to any other discipline imposed. DOH vs, Jessica Lauren Robinson, R.N. 5 Case No: 2016-13930

Docket for Case No: 17-006705PL