Building the Case¶

The Paper Trail documents the institutional response to Kevin Bass's speech — from "obviously protected" to emergency removal. This page documents what happened in between: how the disciplinary case itself was constructed.

The institution needed three "below expectations" professionalism evaluations to trigger the formal conduct process. Here is how they got them — and what they built on top.

The Three-Complaint Trap¶

Under School of Medicine policy, three "below expectations" ratings in professionalism triggered automatic referral to the Student Professional Performance Conduct Committee (SPPCC). Two of the three concerned the same incidents.

Brown forwarded NP Madeleine's concerns to Forbes and Zavala. Both Brown and Madeleine then filed separate "below expectations" professionalism evaluations — double-counting a single set of observations to produce two of the three complaints needed to trigger SPPCC. (Complaint ¶67A)

The third evaluation was filed by Dr. Blann after only three hours of direct contact. Blann rated Patient Care as "Did better than I though [sic] he would" — revealing preconceived negative expectations — while simultaneously rating Professionalism as "I have worries" without identifying any specific incident. (FERPA Doc 0542)

None of the three evaluators communicated any concern to Kevin before filing.

The Fabricated Allegation¶

On June 21, 2023, Williams and Nunez presented a sexual misconduct allegation against Kevin.

On July 20, 2023, Forbes identified the source — Dr. Zavala — who then called Kevin directly.

Forbes confirmed the denial. Yet the fabricated allegation was still used in professionalism proceedings against Kevin. (FERPA Doc 0835; Complaint ¶172(d))

Zavala's own formal evaluation of Kevin — completed June 24, 2023, just sixteen days after her negative email to Forbes — rated his behavior as "meets expectations." (FERPA Doc 0542)

The formal evaluation and the informal email told opposite stories. The evaluation was the official record. The email was for the file.

The No-Notice Pattern¶

Across nearly every professionalism complaint, the evaluator gave Kevin positive or neutral feedback during the rotation and filed a formal complaint without ever raising the concern.

Of the evaluators whose assessments were used against Kevin, only Dr. Eboh provided any contemporaneous feedback. (Complaint ¶94)

If the behaviors were serious enough to warrant formal misconduct reports, they were serious enough to warrant a conversation with the student.

The Professionalism Workaround¶

On or about August 22, 2023, Cobbs documented the strategy.

First Amendment protection explicitly acknowledged. Then circumvented through "professionalism." (Complaint ¶72)

The SPPCC Letter — Drafted by the Prosecution¶

The adverse SPPCC letter used against Kevin at the hearing was not an objective institutional assessment. It was collaboratively constructed.

Document metadata shows an earlier draft (FERPA Doc 0436) lacked a "specific behaviors" section. That section appeared only after Forbes and Cobbs edited the file (FERPA Doc 0438), changing it from a single "event" to plural "events."

At least five people drafted and reviewed the adverse letter — then presented it as an objective assessment. (Complaint ¶69)

The Appeal Win That Changed Nothing¶

On September 7, 2023, Interim Dean DeToledo confirmed the SPPCC appeals panel "voted to support [Kevin's] appeal" — citing "lack of specificity in descriptions of the lapse in professionalism." Trotter independently confirmed the basis: he listened to the recordings and found that not a single professionalism incident had been cited in the testimony.

The same day:

Williams — the Senior Associate Dean who administered the entire SPPCC process, received Kevin's appeal, and briefed the appeal committee — drafted the appellate authority's decision on those very proceedings. (Complaint ¶55)

Despite Kevin winning the appeal, DeToledo imposed a structural trap: automatic triage to the conduct board for any future complaint. This stripped Kevin's right to informal complaint disposition. Every subsequent complaint — no matter how minor — would bypass the Student Conduct Administrator and proceed directly to the board.

The volume of complaints that later became the basis for Kevin's dismissal reached the board only because this safety valve was removed after a proceeding where zero professionalism incidents had been identified. (Complaint ¶68)

Within eleven days of the appeal, two new evaluations appeared containing unprecedented specificity — providing "precisely the detail that would fill in the gap" the appeal had exposed.

The Complaint Factory¶

Forbes directed the filing. Wilson complied.

On September 18, 2023, Wilson filed a misconduct report at Forbes's direction. Forbes then had herself listed as one of four "victims" on Wilson's report. Wilson requested "suspension or dismissal" as remedy — while simultaneously acknowledging in recorded conversations that Kevin's behavior was "not malicious" and "not... on purpose." (Complaint ¶¶55(c), 141)

Wilson did not speak to Kevin before filing.

Administrators did not passively receive complaints. They actively directed their creation and controlled their routing.

Even after the hearing process was underway and Kevin had been removed from campus, Forbes was still collecting. On November 27, 2023 — sixteen days after removal — Findler emailed Trotter (CC Forbes): "Rachel asked me to forward an evaluation to you for Kevin Bass from a psychiatry resident that gave a 'low score' alert." (FERPA Doc 1283)

The CPS Report¶

In late September 2023, hospital therapist Aundra Conyer — a sexual abuse expert — directed Kevin to file a CPS report regarding a sexually abused minor and told him he had a legal obligation to do so.

Nunez told Kevin he "didn't need to." Kevin followed the expert's direction.

The evaluation recharacterized compliance with a mandatory reporter obligation as insubordination. The investigation was conducted by Dr. Haynes — a urologist, not Pediatrics faculty — and approved by Kunkov, the Pediatrics department chair. The department investigated itself. Kevin was never interviewed. (Complaint ¶97)

Jensen's evaluation then cross-referenced the same CPS incident — characterizing Kevin's compliance as "not follow[ing] instructions from the attending" — despite having no firsthand involvement. Cascade contamination between evaluators. (Complaint ¶98)

Shut Down the Investigator¶

Investigator J. Edward Bates conducted multiple grievance investigations involving Kevin but never contacted Kevin for any of them.

In a pediatrics-related investigation, Bates requested underlying clerkship evaluations and expressed interest in interviewing Kevin. After communicating with Cobbs and Conser:

Bates did not receive the requested evaluations. No interview occurred. He then issued reports across multiple complaints without ever hearing from Kevin.

Kevin filed seven formal mistreatment grievances. In every investigation, the respondent was interviewed along with multiple additional witnesses. Kevin was never interviewed for any of the seven. His overall record: 1-for-7. The sole favorable outcome involved a non-faculty staff member. (Complaint ¶93)

Title IX Forum-Shopping¶

The formal report was not filed by the complainant. TTUHSC official Conser filed it as a "Title IX Mandatory Reporter" on August 1, 2023.

Under the Title IX process then in effect, Kevin would have been entitled to a live hearing with cross-examination, equal access to evidence, and a trained impartial decision-maker. The conduct process provided an advisor "not permitted to speak," a hearing officer who banned all objections, and a 15-to-0 witness asymmetry. (Complaint ¶102)

When Kevin filed his own Title IX report, Collins declined to investigate: "The Title IX Office will not be participating in the adjudication process at this time" — and forwarded Kevin's complaint directly to Trotter, the Student Conduct Administrator building the case against him.

The Grade Override¶

Between the tweet and the hearing, Kevin's passing numerical grade in Pediatrics was converted to a Fail.

When an institution overrides a passing grade to impose a failing one, the resulting "academic" record cannot serve as an independent basis for dismissal. It is itself evidence of predetermined outcome. (Complaint ¶172(c))

The Evidence Assembly¶

Favorable evidence was suppressed. Adverse evidence was manufactured.

Cobbs blocked favorable evaluations. When a colleague sought Kevin's inpatient clerkship evaluations: "Just spoke with Dr. Cobbs and unfortunately can't provide the other clerkship evaluations from inpatient." (FERPA Doc 1236)

Trotter's favorable report was suppressed. Trotter requested a performance report from Family Medicine. It was favorable. Trotter polled other faculty about Thomas's sleeping claim; none corroborated it. Neither the favorable report nor the contradicting responses were presented at the hearing. Only adverse evidence was presented. (Complaint ¶73)

Only Wilson's sphere produced adverse evaluations. Five of six Pediatrics evaluations originated from the department where Forbes controlled the campus and Wilson oversaw the department. Walker and Wilson filed on the same day (September 18). Eboh discussed evaluations with Wilson (September 21). Jensen cross-referenced Nunez's evaluation. The pattern was not uniform poor performance — it tracked Wilson's administrative reach. (Complaint ¶100)

The Comparator¶

Dr. Autum DeSoto — the outpatient Pediatrics physician outside Wilson's sphere — spent approximately three times more contact hours with Kevin than any other Pediatrics evaluator.

No evaluations were collected from Emergency Medicine or overnight outpatient rotations, despite evaluation forms being sent. The record presented at the hearing contained only evaluations from Wilson's sphere of influence. (Complaint ¶100)

Every adverse Pediatrics evaluation came from inpatient settings where Wilson had direct control or connections. The evaluator with the most contact time — on outpatient, outside that sphere — recommended Kevin for residency.

The Result¶

On November 3, 2023, Kevin posted a tweet. The file was ready. What happened next is documented in The Hearing.

Source and Method¶

All FERPA documents are identified by the numbering system Kevin Bass used during the January 5–8, 2026 FERPA inspection. Because TTUHSC restricted inspection to in-person, view-only access with no copying, these documents were transcribed by hand and are presented in digitally reformatted form.

Complaint paragraph numbers refer to the Third Amended Complaint, Case No. 5:25-cv-00244-H-BV (N.D. Tex.). Hearing transcript citations refer to the December 11, 2023 disciplinary proceeding, which TTUHSC controlled and recorded.

Related Pages¶

• The Paper Trail — The institution's own emails, from "obviously protected speech" to emergency removal
• The Hearing — From emergency removal through the fourteen-hour hearing to dismissal
• The Recordings — 25 hours of audio — what the institution claimed versus what the recordings show
• The Squeeze: Documents — From $24K tuition balance to collection agency
• Court Filings — Download the complaint and response to motion to dismiss
• FERPA Evidence Index — All 35 FERPA documents cited in the complaint