STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 156-3189 LULA G, FAISON, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against LULA G. FAISON. 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 1042106, covering the areas of English for Speakers of Other Languages (ESOL), Prekindergarten/Primary Education and Exceptional Student Education (ESE), which is valid through June 30, 2021. 2. At all times pertinent hereto, the Respondent was employed as an ESE Teacher at Pompano Beach Elementary School in the Broward County School District. MATERIAL ALLEGATIONS 3. On or about April 18, 2016, Respondent failed to protect the safety of a second grade student, A.J., when she failed to ensure that A.J. returned to her classroom after recess. When A.J. refused to leave the school playground, Respondent lefi A.J. unattended, and as a result, A.J. left the school campus without supervision. 4. During the 2015-2016 school year, Respondent was frequently absent, missing 31 days of work, was tardy to work 20 times, failed to timely complete individual education plans LULA G. FAISON Administrative Complaint Page 2 of 3 (IEPs), and was insubordinate to her Principal when she refused to speak with the Principal regarding the allegations in paragraph 3 herein. Respondent’s conduct has resulted in her loss of effectiveness as a school district employee as evidenced by: a) The refusal of other employees to work in Respondent’s classroom; b) The unsafe conditions in Respondent’s classroom; c) The behavioral performance of Respondent’s students; and d) The negative impact of Respondent’s behavior on the school’s climate and culture. 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)(), 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. (SIGNATURE ON FOLLOWING PAGE) LULA G. FAISON 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 YUL day of “Milky ,2017. PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 18-002093PL