STATEOF FLORIDA... - DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, ve CASE NO, 2018-23700 AMANDA DENISE STEWART, R.N., RESPONDENT. / ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, Department of Health, by and through its undersigned counsel, and files this Administrative Complaint before the Board of Nursing against Respondent, Amanda Denise Stewart, 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 Administrative Complaint, Respondent was a registered nurse (R.N.) within the state of Florida, having been issued license number RN 9476211. "3, Respondent's address of record is 2401 Lakeshore Drive, Old Hickory, Tennessee 37138. 4. Respondent may also be found at 800 Prudential Drive, Jacksonville, Florida 32207; or 996 Pleasant Run Road, Smyrna, Tennessee 37167. 5. On or about August 15, 2018, Respondent submitted to an independent medical evaluation conducted by M.G., M.D. 6. Onor about August 15, 2018, Dr. M.G. diagnosed Respondent with alcohol use disorder,- mild; opioid use disorder, mild in sustained remission; and benzodiazepine use disorder, mild in sustained remission. ‘7. Dr. M.G. recommended that Respondent complete an intensive outpatient program to treat her substance use disorders. 8. Onor about August 15, 2018, Dr. M.G. opined that Respondent cannot be endorsed to practice nursing “at this time.” 9. Section 464.018(1)(j), Florida Statutes (2018), subjects a licensee 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. Department of Health v. Amanda Denise Stewart, R.N. 2 Case Number 2018-23700 : : 10. As set forth above, Respondent is unable to practice nursing with reasonable skill and safety. 11. Based on __ the foregoing, Respondent violated Section 464.018(1)(j), Florida, Statutes (2018), 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. [Remainder of page intentionally left blank| Department of Health v. Amanda Denise Stewart, R.N. 3 Case Number 2018-23700 se WHEREFORE, the 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 the 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 12th day of August _, 2019. FILED ee TEP UTY ee sistant Genéral Counsel CLERK: Bridget Coatey fa. Bar No. 98772 0 DATE: S~(2-Z2O(G Florida Department of Health Prosecution Services Unit. - 4052 Bald Cypress Way, Bin #C65 Tallahassee, FL 32399-3265 Telephone: (850) 558-9898 Facsimile: (850) 245-4662 © Email: judson.searcy@flhealth.gov PCP: 08/ 12/2019 PCP Members: Talmadge & Stone-Gale Department of Health v. Amanda Denise Stewart, R.N. 4 Case Number 2018-23700 . .- 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. Department of Heafth v. Amanda Denise Stewart, R.N. 5 Case Number 2018-23700

Docket for Case No: 21-000868PL