The Hearing¶

The Paper Trail documents the institutional emails. Building the Case documents how the complaints were manufactured. This page documents what happened when the institution executed the result: from emergency removal to a fourteen-hour hearing to dismissal.

Eight of the institution's own officials said Kevin Bass was not a threat. The university removed him from campus, circulated a BOLO poster, and held a hearing where the administration called fifteen witnesses and Kevin was permitted zero.

November 3, 2023 — The Tweet¶

The tweet did not name TTUHSC, identify any person, or call for violence. The same day, Kevin submitted a formal appeal of his pediatrics clinical assessment through institutional channels (FERPA Doc 1132) — actively engaging with the processes TTUHSC provided.

Within 24 hours, he was removed from campus.

The Threat Assessment¶

Williams completed the Interim Suspension Questionnaire (Exhibit TAC-13). The pattern in the answers reveals what the institution actually meant by "threat."

Seven of ten questions answered affirmatively. Each affirmative answer depends on characterizing protected activity — speech, grievance-filing, petitioning — as threatening conduct. The three "No" answers were questions where fabrication was impossible. (Complaint ¶62)

"Kevin Is Not a Danger to Anyone"¶

The institution's own counselor — the only mental health professional who had worked with Kevin — wrote a letter three days before the hearing.

Korinek was excluded from the decision:

The only qualified mental health professional was excluded from the threat determination. Her associate was present but not permitted to speak. (Complaint ¶57)

Eight Officials Said No Threat¶

Meanwhile: the BOLO poster said "call 911." (Complaint ¶180)

The Circularity Trap¶

The threat assessment used Kevin's grievances as context for the emergency. The emergency eliminated the grievance process. The unresolved grievances were then cited at the hearing as evidence of Kevin's "disruptive pattern."

Wilson testified under oath that faculty fear was "fear of retaliation" — meaning that Kevin would file complaints about them, not that he posed physical danger. When the "threat" justifying emergency removal was that a student might petition, the emergency was derived from protected activity itself. (Complaint ¶60)

The BOLO¶

Williams's own questionnaire answered "No" to terroristic threats. TTUHSC's own threat assessment protocol contains a mandatory decision point: "Is There any Physical or Other Credible Evidence?" If no, the protocol directs: "No Security Hold or Criminal Trespass is Issued."

TTUHSC imposed both. (Complaint ¶61)

General Counsel Posey confirmed the cause: "The outcome of the tweet and the perceived threat of that tweet is the reason he is not allowed on campus right now." And: "We haven't received a specific complaint on that." (Complaint ¶113)

At the hearing itself — seven weeks later — Kevin carried a large backpack into the building. No one searched the backpack, searched Kevin's person, or conducted a pat-down. No security guard or police officer escorted him. If he was dangerous enough for "call 911," why no security at the hearing? (Complaint ¶91)

The Campus Ban¶

The ban lasted approximately one year. During that time:

Approved: Picking up his child from daycare (a dozen times). Picking up prescription medication (several times). Visiting his psychotherapist Dr. Korinek (two or three times).

Denied: Meeting prospective defense witnesses.

Safety exception for daycare pickup. No exception for witness recruitment. The ban's operative function was not safety but litigation advantage.

When Kevin went to pick up his three-year-old from the campus daycare, he was given a police escort — an armed escort for a parent's daycare pickup, triggered by a BOLO whose own underlying threat assessment found "no threat." (Complaint ¶127)

The Fear Campaign¶

On November 4, 2023, Forbes emailed more than 30 recipients:

The next day:

A student responded the next day:

Forbes created the fear, then forwarded the panicked response to Williams and DeToledo as evidence. Forbes had access to the Threat Assessment Questionnaire (Williams checked "No" on terroristic threats) and later the neuropsychological evaluation ("not indicative of... violence"). She never corrected the record with students. (Complaint ¶119)

By 7:55 PM on November 4 — the same day — a fellow medical student had already compiled the BOLO flyer, the tweet, and the Forbes email screenshot into a single package and forwarded all three to Cobbs, Williams, and DeToledo. (FERPA Doc 1499)

"Withdraw or Face Hearing"¶

Withdraw permanently or face a hearing. The institution had already decided on removal and offered the hearing not as a neutral fact-finding process but as the consequence for refusing to leave voluntarily. (Complaint ¶54)

The Hearing Officer¶

TTUHSC selected Darren G. Gibson as outside Hearing Officer. Gibson was not a neutral adjudicator.

TTUHSC's own hearing policy (HSC OP 77.13 §5.d(1)) requires that hearing officers "must have no direct interest in the outcome of the case and shall decline to serve if a conflict of interest, or an appearance of a conflict of interest, exists." (Complaint ¶80)

Gibson also acknowledged the constitutional dimension at the hearing: "There is a First Amendment issues related to someone's free speech." (Complaint ¶134(e))

The Accommodation Request¶

Three days before the hearing, Kevin's attorney emailed the Board Chair.

Kevin also submitted a formal SDS application on December 8, 2023, requesting accommodations "generally but in particular concerning a student conduct hearing scheduled for Dec. 11 at 8 AM." (FERPA Doc 1509; Exhibit TAC-7)

The application was printed from TTUHSC's Banner system on December 12 — the day after the hearing. SDS did not issue any accommodation letter before the hearing occurred.

TTUHSC's own policy (OP 77.14) requires registration, documentation review ("up to two weeks"), an interactive meeting, and a Letter of Accommodation. Between Friday afternoon and Monday morning, one partial business day existed. The institution controlled the hearing date, chose not to postpone, and created a timeline that made compliance with its own accommodation policy structurally impossible. (Complaint ¶46)

December 11, 2023 — The Hearing¶

Gibson's accommodations for a neurodevelopmental disability in a fourteen-hour adversarial proceeding: water, snacks, breaks, and a support person — logistical comforts available to any participant.

Every substantive accommodation — attorney-assisted questioning as a communication aid, written-format delivery, structured turn-taking, postponement for SDS determination — was denied. (Complaint ¶49)

Kevin's neuropsychological evaluation had specifically concluded that he "should have appropriate representation and should not be permitted to represent himself." The Student Handbook required precisely that — self-representation with a silent advisor against ten institutional witnesses over fourteen hours. (Complaint ¶52)

Witnesses¶

The administration presented fifteen witnesses (drawn from eighteen authorized — including three added day-of without advance notice). Kevin was permitted zero.

Gibson allowed the University to add Dr. Erwin as a witness that morning — stating "I'm going to allow Dr. [Erwin] to be added as a witness." In the same proceeding, Gibson denied Kevin's neuropsychologist — the only expert who could provide clinical context — because "the university did not have time to identify [a] rebuttal witness." The University had no advance notice of Erwin's testimony either. (Complaint ¶50)

Why Kevin had no witnesses:

• Frantz had worked with Kevin for weeks, written favorable evaluations, and submitted a favorable letter of support — yet would not testify, citing "not knowing [Kevin] well enough."
• Korinek reviewed the case materials, concluded the process appeared unfair, and decided testimony would be futile given the appearance of predetermined outcome. (Complaint ¶148)

Time¶

Gibson declared at the outset: "my decisions are final."

Wilson's examination alone ran approximately 80 minutes — against a stated 30-minute-per-witness limit. Gibson then told Kevin: "you have 20 more minutes" for all remaining questioning.

The administration presented for approximately ten hours. Kevin's testimony did not begin until approximately 6:45 PM. By that point — after fourteen hours without adjusted ADHD medication — Kevin was missing more than fifty percent of what was said and could not formulate adequate cross-examination. (Complaint ¶¶51, 52A)

Evidence¶

Gibson admitted only a redacted version of the neuropsychological evaluation, excluding the accommodations section as "outside the Board's scope." The full evaluation concluded Kevin was "not indicative of increased chances toward criminal activity or violence" and described him as "a sensitive and gentle individual." Gibson excluded it. (Complaint ¶¶39(e), 48)

Gibson banned contemporaneous objections while allowing the University to raise procedural points throughout. He framed the proceeding as "not an adversarial courtroom" to deny Kevin cross-examination — then invoked "legal perspective" concerns to restrict Kevin's participation. Legal authority invoked to restrict. Legal protections denied because the proceeding was "not legal." (Complaint ¶146)

The Deliberation Room¶

Gibson announced that "all advisors [and] parties are excluded from [the] deliberation process."

Gibson remained.

Trotter — the Student Conduct Administrator who had designed the compromise hearing structure, the administrator most familiar with the complaints, grievances, and Kevin's circumstances — sought to participate in deliberations. He was refused.

The institution's paid litigation counsel shaped the Board's findings from inside the deliberation room. The one administrator who had shown Kevin procedural consideration was excluded from it.

The Board's Decision¶

The Board's letter (December 27, 2023) used "Non-Academic Dismissal" three times, citing Code of Conduct Part II.G.2.g — never academic standards. A word count: 87 disciplinary references versus zero academic-performance references. No GPA, board scores, or course grades. (Complaint ¶82)

The Board never found that Kevin actually posed a safety threat:

The Board's two most relied-upon witnesses were Wilson and Erwin — simultaneously the principal complaint-generators who had spent months constructing the adverse file. The Board stated their testimony was "particularly relevant" because "based on their observations, they did not believe Dr. Bass was fit to continue as a medical student based on professionalism concerns." The Board treated advocacy as observation. (Complaint ¶142)

The Board rejected disability accommodation as "retroactive leniency" — in the institution's own words. Accommodation is not leniency. It is a legal obligation. (Complaint ¶44)

The Board claimed Kevin's disability was "not disclosed until the morning of the hearing." This is false. Kevin's counsel formally notified TTUHSC three full days before the hearing. (Complaint ¶43)

The Aftermath¶

Within five days of the non-public Board determination:

The procedural phrasing mirrors internal TTUHSC language. Confidential disciplinary information reached external actors who considered themselves participants in Kevin's removal. (Complaint ¶123)

On January 7, 2024, Forbes sent a mass email to over 200 students: "We are one student lighter than last week, and I hope we can all breathe a sigh of relief... just check his Twitter." She attempted to recall the email. In the same message, Forbes announced Wilson's appointment as her replacement — the same Wilson whose 80-minute examination had consumed more time than all of Kevin's participation combined. (Complaint ¶121; see The Paper Trail)

On January 11, 2024, Vice Provost Kruse — designated by Provost D'Agostino — rejected Kevin's final appeal. Kevin had proposed transferring to another campus, taking a leave of absence, and implementing the accommodations in his neuropsychological evaluation. All rejected. The next day, TTUHSC circulated a dismissal memo to seven officials. (Complaint ¶¶114, 125)

Kevin applied to two Caribbean medical schools. Both rejected him based on information TTUHSC provided. (Complaint ¶152)

TTUHSC refused to provide a Dean's letter. (Exhibit TAC-10; Complaint ¶144)

Summary¶

Source and Method¶

Hearing transcript citations refer to the December 11, 2023 disciplinary proceeding, which TTUHSC controlled and recorded. FERPA Doc numbers refer to Kevin Bass's identifiers from the January 2026 inspection, where documents were hand-transcribed during supervised sessions. Complaint paragraph and exhibit references refer to the Third Amended Complaint, Case No. 5:25-cv-00244-H-BV (N.D. Tex.).

Related Pages¶

• The Hearing Officer — The man who wrote the rules, trained universities on them, then judged Kevin's case
• Building the Case — How the complaints were manufactured before the hearing
• The Paper Trail — The institution's own emails, from "obviously protected speech" to emergency removal
• 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