RUTH C. PREVOR, APPELLANT,
v.
DEPARTMENT OF HEALTH, BOARD OF PSYCHOLOGY, APPELLEE
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
Dr. Prevor appealed the Board of Psychology's denial of her application for licensure by endorsement in Florida based on her lack of APA programmatic accreditation for her 1988 Ph.D. from Carlos Albizu University. The court affirmed the Board's decision, holding that Florida's statute requires the psychology program to have been accredited by the APA at the time of the applicant's enrollment and graduation, and that the Board's prior erroneous approval of a similarly-situated applicant does not require acceptance of comparability studies for future applications.
The court held that Florida's statute requires a doctoral degree in psychology to have come from a program with APA programmatic accreditation at the time the applicant was enrolled and graduated, and Dr. Prevor's degree did not meet this requirement. The court further held that the Board's prior mistake in granting a previous applicant's license based on an invalid comparability study does not entitle Dr. Prevor to a license on that same erroneous basis, and the Board is not required to accept comparability studies for future applications under the statute.
[1] Licensure by endorsement requires an applicant to possess a doctoral degree in psychology from an accredited educational institution with programmatic accreditation from…
[2] Programmatic accreditation for a doctoral degree in psychology, for purposes of Florida licensure by endorsement, requires accreditation by the American Psychological Ass…
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“a "doctoral degree in psychology" means "a Psy.D., an Ed.D. in psychology, or a Ph.D. in psychology" from an accredited educational institution with a psychology program that, "at the time the applicant was enrolled and graduated, had programmatic accreditation from an agency recognized and approved by the United States Department of Education."”
Establishes the statutory definition of a qualifying doctoral degree requiring programmatic accreditation at the time of enrollment and graduation
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceDr. Prevor is a psychologist licensed in Puerto Rico with more than twenty years of experience. She obtained a Ph.D. in psychology from Carlos Albizu …
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse Licensure By Endorsement cases and more on FLexlaw
Ruth C. Prevor (“Dr. Prevor”) appeals from a final order entered by the State of Florida, Board of Psychology (“the Board”), denying her Application for Li-censure by Endorsement. As the Board *98properly concluded that Dr. Prevor failed to meet the educational requirements for licensure by endorsement, we affirm.
Dr. Prevor filed an Application for Li-censure by Endorsement pursuant to section 490.006(l)(c), Florida Statutes (2014), which provides as follows:
(1) The .[Department [of. Health] shall license a person as a psychologist ... who, upon applying to the department ..., demonstrates ... to the [B]oard [of Psychology] that the applicant:
(c) Possesses a doctoral degree in psychology as described in s. 490,003 and has- at least. 20 years of experience as a licensed psychologist in any jurisdiction or territory of the United States • within 25 years preceding the date of application.
Section 490.003(3)(b), Florida Statutes (2014), provides in relevant part that a “doctoral degree in psychology” means “a Psy.D., an Ed.D. in psychology, or a Ph.D. in psychology” from an accredited educational institution with a psychology program that, “at the time the applicant was enrolled and graduated, had programmatic accreditation from an agency recognized and approved by the United States Department of Education.” § 490.003(3)(b)2. (emphasis added). To meet the programmatic accreditation requirement of section 490.003(3)(b)2„ the psychology program must be accredited by the American Psychological Association (“APA”),
Dr. Prevor, a psychologist licensed in Puerto Rico with more than twenty years of experience, graduated with a Ph.D. in psychology from Carlos Albizu University in Puerto Rico in 1988. At that time, the psychology program at Carlos Albizu University was not accredited by the APA.1 Based on the lack of “programmatic accreditation,” the Board concluded that Dr. Prevor’s degree did not meet the educational requirements of section 490.003(3), and therefore, it denied her application. We find no error in the Board’s interpretation of sections 490.006(l)(c) and 490.003(3)(b).
Dr. Prevor further argues that, even if her degree does not satisfy the educational requirements, the Board should nonetheless allow her to submit a comparability study that would allow her to establish that the Ph.D. degree she obtained at Carlos Albizu University in 1988 meets the requirements of an APA-accredited program. In making this argument, Dr. Prevor emphasizes the fact that the Board allowed one of her similarly-situated classmates to submit a comparability study, and thereafter, the Board approved his application for licensure by endorsement under section 490.006(l)(c).2
The Board acknowledges that it allowed Dr. Prevor’s classmate to submit a comparability study and that it subsequently approved his application. The Board, however, correctly submits that it mistakenly did so because there is no provision in section 490.006(l)(c) or 490,003(3)(b) that provides that an applicant seeking licen-sure by endorsement under section 490.006(l)(c) can establish the educational requirements through a comparability study. However, the Board’s mistake in *99granting a previous application on an invalid basis does not entitle Dr. Prevor to a license on that same erroneous basis. In other words, the Board’s prior mistake does not require the Board to accept comparability studies for future applications for licensure by endorsement under section 490.006(l)(c). We therefore affirm the order under review denying Dr. Prevor’s application.
The remaining arguments raised by Dr. Prevor do not merit discussion.
Affirmed.