STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 145-2863 LOVELY GOODMAN, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against LOVELY GOODMAN. 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 842052, covering the area of Guidance and Counseling, which is valid through June 30, 2018. 2. At all times pertinent hereto, the Respondent was employed as a Guidance Counselor at Northeast High School in the Broward County School District. MATERIAL ALLEGATIONS 3. In or around the years 2011-2013, Respondent failed to follow Broward County School District (District) policy for grade changes made through “grade averaging.” District policy 6000.1 (policy) for grade averaging, in accordance with section 1003.436, Florida Statutes, provides in pertinent part: a. Starting in 2009-10, for the purpose of graduation, grade averaging of the two semesters for a year-long course will be permitted when one is a failing grade and the other grade is a C or higher. LOVELY GOODMAN Administrative Complaint Page 2 of 3 b. A student enrolled in a full-year course shall receive one-half credit if the student successfully completes either the first half or the second half of a full-year course but fails to successfully complete the other half of the course and the averaging of the grades obtained in each half would not result in a passing grade. c. A student enrolled in a full year course shall receive full credit if the student successfully completes either the first half or the second half of a full-year course but fails to successfully complete the other half and the averaging of the grades obtained would result in a passing grade, provided that the student receives a grade of C or better on the final examination in the semester failed and meets District policies for attendance (applied to the class in question for the purpose of grade averaging), homework, participation and other indicators of performance. 4. Given Respondent was employed as a Guidance Counselor at all times relevant hereto, she was responsible for knowing and following the District policy and Florida law. Despite having known or should have known the District policy and Florida law, Respondent inappropriately applied grade averaging to over 50 final grades for students when she failed to ensure that the students met the District’s attendance requirements or received a grade of C or better on the final exam in order to be eligible for grade averaging. 5. Some of the students whose grades were inappropriately grade averaged by Respondent graduated from high school with a standard diploma when they would not have met the requirements for graduation without the inappropriate grade averaging, 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)q), 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. LOVELY GOODMAN Administrative Complaint Page 3 of 3 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. COUNT 5: 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 onthis (6™ dayor March 2018. Mbyte} PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 18-004184PL