STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 123-3213 FELISIA CIRTIRIA HILL, . Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against FELISIA CIRTIRIA HILL. 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 808607, covering the areas of Educational Leadership, Elementary Education, English for Speakers of Other Languages (ESOL) and Reading, which is valid through June 30, 2019. 2. At all times pertinent hereto, the Respondent was employed as an Elementary Teacher at Glade View Elementary School in the Palm Beach County Schoo! District. MATERIAL ALLEGATIONS 3. During the 2010/2011 school year, Respondent claimed disability benefits between November 18, 2010, and February 20, 2011. During this time period, Respondent submitted invoices to school district(s) for payment of tutoring services provided by Respondent while away from her teaching position on claimed disability. During the period of time that Respondent was collecting disability benefits, she fraudulently provided false information regarding her working status to the insurance company providing the benefit checks. At least FELISIA CIRTIRIA HILL Administrative Complaint Page 2 of 4 twice, Respondent told insurance representatives that she had not been working and was not receiving any other income during the time she was collecting disability benefits. 4, During the 2010/2011 school year, Respondent operated Glades Extreme Tutoring, Inc. which provided tutoring services at a rate of $70 per hour to students from poorly performing schools. Glades Extreme Tutoring, Inc. was approved as a Supplemental Education Service (ESE) provider allowing them to be paid by the districts for the tutoring up to $1439 per student. Respondent conducted her business in a fraudulent manner as evidenced by the following: a) Respondent billed districts for services she did not provide. b) Respondent fraudulently verified services by forging signatures and/or initials of parents and/or students. c) Respondent conspired to receive and did receive district funds that she did not earn and to which she was not entitled and converted those funds to her own use. d) By billing for specific students and then not providing those students services, Respondent deprived those students of possible future benefits because funds allocated for those specific students had been spent. e) After the fact, and with knowledge or belief that an investigation had been opened, Respondent attempted to convince parents and/or students to lie and say that they had received services to protect Respondent. f) After the fact, and with knowledge or belief that an investigation had been opened, Respondent attempted to use money to bribe parents and/or students to testify falsely on Respondent’s behalf. 5. On or about March 16, 2012, Respondent was charged in Palm Beach County with 11 counts of Grand Theft, six counts of Petit Theft and three counts of Tampering with Witness, Victim or Informant. On or about April 20, 2016, 5 counts of Grand Theft were nolle prossed in Palm Beach County subsequent to Respondent’s completion of a deferred prosecution program. 6. On or about May 5, 2012, Respondent was charged in Okeechobee County with Felony Theft Over $300 and three counts of Scheme to Defraud. On or about March 26, 2016, FELISIA CIRTIRIA HILL Administrative Complaint Page 3 of 4 one count of Felony Grand Theft was nolle prossed in Okeechobee County subsequent to Respondent’s completion of a pretrial intervention program. On or about March 29, 2012, one count of Organized Fraud/Less Than $20,000 was nolle prossed in Okeechobee County subsequent to Respondent’s completion of a pretrial intervention program. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of section 1012.795(1)(d), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude as defined by rule of the State Board of Education. COUNT 2: 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 3: 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 4: 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 leaming and/or to the student’s mental health and/or physical health and/or safety. COUNT 5: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(2)(b)2, Florida Administrative Code, in that Respondent has intentionally distorted or misrepresented facts concerning an educational matter in direct or indirect public expression. COUNT 6: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(2)(b)3, Florida Administrative Code, in that Respondent has used institutional privileges for personal gain or advantage. COUNT 7: 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 8: 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. FELISIA CIRTIRIA HILL Administrative Complaint Page 4 of 4 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 LOLA day of “UY EBLE, 2016. PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 18-005312PL