Court Filings¶

Bass v. Texas Tech University Health Sciences Center et al. Case No. 5:25-cv-00244-H-BV (N.D. Tex., Lubbock Division)

Active Filings¶

Third Amended Complaint (TAC)¶

The operative complaint, filed February 2026, asserts seven claims against eleven defendants arising from the dismissal of Kevin Bass from TTUHSC's medical school and subsequent institutional actions.

Claims asserted:

1. Section 504 Disability Discrimination
2. Title II ADA (Prospective Relief)
3. Due Process (Procedural) -- 42 U.S.C. 1983
4. Stigma-Plus / Liberty Interest -- 42 U.S.C. 1983
5. First Amendment Retaliation -- 42 U.S.C. 1983
6. ADA/504 Retaliation -- 42 U.S.C. 12203
7. Name-Clearing Hearing -- 42 U.S.C. 1983

Download Third Amended Complaint (104 pages, PDF)

Plaintiff's Response to Defendants' Motion to Dismiss¶

Filed February 2026. Responds to each ground raised in the Defendants' Motion to Dismiss with citations to the factual record and applicable law.

Download Response Brief (32 pages, PDF)

Download Response Appendix (92 pages, PDF)

Defendants' Motion to Dismiss¶

Filed January 2026 by counsel for the TTUHSC defendants. Seeks dismissal of all claims on qualified immunity, sovereign immunity, and failure-to-state-a-claim grounds.

Download Motion to Dismiss (PDF)

Case Information¶

Related Pages¶

• The Paper Trail -- The institution's own emails, in chronological order
• FERPA Evidence Index -- 35 key education records cited in the complaint
• Legal Case Overview -- Hearings, transcripts, and due process actions
• Case Arc Timeline -- Chronological overview of major events
• Key Exhibits -- Curated selection of important documents
• Evidence & Exhibits -- Full thematic evidence index