STATE OF FLORIDA EDUCATION PRACTICES COMMISSION RICHARD CORCORAN, as Commissioner of Education, Petitioner, vs. CASE NO. 190-0168 CHELSEA HORSMAN, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Richard Corcoran, as Commissioner of Education, files this Administrative Complaint against CHELSEA HORSMAN. 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 1216393, covering the area of Speech Language Impaired, which is valid through June 30, 2023. 2. At all times pertinent hereto, the Respondent was employed as a Speech Language Pathologist in the Pinellas County School District. MATERIAL ALLEGATIONS 3. On or about August 21, 2018, Respondent’s conduct was grossly immoral when she pointed a firearm at the chest of Anthony Russ, without provocation. Respondent was arrested and charged with Aggravated Assault (Deadly Weapon). She subsequently enrolled in a diversion program for thirty-six months. Probable Cause Letter and Administrative Complaint.-2 CHELSEA HORSMAN Administrative Complaint Page 2 of 2 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. 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. 4 EXECUTED on this 2" dayot_ November _, 2020. LM RICHARD CORCORAN, as Commissioner of Education State of Florida Probable Cause Letter and Administrative Complaint.-3

Docket for Case No: 21-001088PL