STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 167-3352 LATUNYA GIBBS, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against LATUNYA GIBBS. 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 I. The Respondent holds Florida Educator’s Certificate 719693, covering the areas of Educational Leadership, English for Speakers of Other Languages (ESOL), Prekindergarten/Primary Education and Primary Education, which is valid through June 30, 2020. 2. At all times pertinent hereto, the Respondent was employed as a Third Grade Teacher at Mirror Lake Elementary School in the Broward County School District. MATERIAL ALLEGATIONS 3. During the 2015-2016 and 2016-2017 school year, Respondent submitted fraudulent Family Medical Leave Act (FMLA) paperwork when requesting leave during the school years. The paperwork contained a falsified signature of a medical professional. 4. During the 2016-2017 school year, Respondent fraudulently submitted a certificate of completion that indicated that she had completed test administrator training for the Florida Standards Assessment (FSA) when she did not participate in the training. LATUNYA GIBBS Administrative Complaint Page 2 of 3 5. During the 2016-2017 school year, Respondent submitted fraudulent third grade portfolios for the students in her class. The portfolios could be used in lieu of a passing score on the FSA as justification for promotion. The portfolios submitted by Respondent suggested that all of her students received a score of 100 on each of the portfolio standards. When the portfolios were checked by the school’s administration, they found that the submissions had been improperly graded and administered. The submissions resulted in Respondent’s students being retested and rescored on the portfolio and three students being promoted to the next grade without qualifying for promotion. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: 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 2: 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 3: 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 4: 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) LATUNYA GIBBS 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 (6 dayot (Yacch _.2018 PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 19-006756PL