LAS VEGAS (CN) - A Western Nevada College student claims in court that her human sexuality instructor required students to masturbate to pass his class, made them keep sex journals for class discussion, was obsessed with women's orgasms and told the class "that he will increase their sexual urges to such a height that they won't be able to think about anything other than sex."
Plaintiff K.R. sued Western Nevada College, her instructor Tom Kubistant, Kubistant's department chairman Robert Morin, and college president Carol Lucey, in Federal Court.
K.R. says she enrolled in Kubistant's Human Sexuality class in the fall of 2011, figuring it would help her in her profession as a social worker. The class was part of the Psychology Department at the college's Carson City campus.
On the first day of class, K.R. says, she was shocked when "Kubistant informed the class that he will increase their sexual urges to such a height that they won't be able to think about anything other than sex."
He then had students compile lists, which he read, of "all the different kinds of sex, i.e. oral sex, vaginal sex, anal sex," the complaint states. He told students to compile a list of different sexual positions. Then Kubistant discussed penis myths, told a sex joke and doled out homework: three journal entries of 250 words each, disclosing their personal sexual thoughts, according to the complaint.
K.R. says Kubistant told the students that their final exam would be an assignment titled, "A Sexual Case Study ... You!" which had to address such topics as early sexual exploration, sexual abuse, loss of virginity, homosexual experiences, promiscuity, cheating, arousal, climaxes, masturbation, sexually transmitted diseases and fetishes.
"Upon reaching Kubistant's requirement that virginity and sexual abuse be disclosed and thoroughly discussed, plaintiff felt pure terror," the complaint states. "As a sexual abuse survivor, plaintiff was horrified at the thought of reliving the sexual abuse endured as a child."
K.R. says, "The memories brought up simply by Kubistant's requirement forced plaintiff to her bed crying for the entire evening."
On the second day of class, Kubistant spent the entire 3-hour period discussing female orgasms and female ejaculation, and played a 90-minute movie of women having orgasmic sex, the complaint states.
It adds: "At the conclusion of the movie, Kubistant asked female students to openly discuss their own orgasms with the class, and then revealed, through reading the students' journals, 'We have virgins in the room!'"
Kubistant offered students extra credit if they bought a stun gun for protection and visited sex stores, K.R. says. In the fourth week, Kubistant spent the 3-hour class discussing masturbation and sex toys, according to the complaint.
"During the class, the journal entry of a student sitting next to plaintiff was discussed in detail with it expanding into a discussion about anal sex; the journal entry disclosed an obsession with licking her boyfriend's ass," the complaint states.
Kubistant then doled out a homework assignment: Students were to masturbate twice as much as they would normally do, and then disclose specifics in their journals, the complaint states.
"Kubistant informed the class that if they were masturbating 14 times a week they must masturbate 28 times a week," according to the complaint.
K.R. claims she informed Kubistant that she did not masturbate, causing Kubistant to order her to masturbate at least three times.
"Kubistant then angrily announced to the entire class they must masturbate if they intended to pass the class," according to the complaint.
"Plaintiff contacted several doctors inquiring as to the appropriateness of Kubistant's behavior," the lawsuit states. "The doctors indicated they were suspicious as to Kubistant's intentions and indicated asking for personal, private, sexual disclosures inappropriate and outside the bounds of ethical standards."
K.R. claims Kubistant also required female students to write a journal about their vaginas, to draw a picture of their own vagina and orgasm, and to indicate where they enjoyed being stimulated. "Again, this was to turn in for Kubistant's purview."
She says the women in the class were required to describe their personal experiences with oral sex, masturbation, standard sex, to identify if they possessed a G-spot and disclose whether they faked orgasms.
"Motivated by her pure and continued terror about memorializing her sexual abuse on paper, plaintiff approached Kubistant requesting modification of the sexual case study assignment," the complaint states. "Kubistant responded angrily, informing plaintiff she had to detail her own sexual history. Kubistant flippantly dismissed plaintiff's request stating that her unease in the assignment, i.e. providing Kubistant with a detailed sexual account of her own life, meant she had 'sexual issues' and that the project would be cathartic."
In the fifth week of class, K.R. says, Kubistant broke the class into groups to do 10-minute presentations on different topics: "One group was responsible for bringing in sex toys; another group was responsible for describing (again) the female orgasm; another group was assigned the topic of nudity. Plaintiff's group was told to demonstrate KY Jelly products and novelty condoms."
K.R. says she asked to do a presentation instead on the health dangers of Vaseline lubricants to women, but "Kubistant flippantly informed plaintiff there was no time for such presentation and that she needed to stick to the topic of novelty condoms."
After 5 weeks of classes, Kubistant had not followed the syllabus, and did not teach the history of sex, cultural influences on sex or prominent sexual studies, according to the lawsuit.
"Instead, the consistent topic Kubistant discussed was the female orgasm. It was a theme and discussed during every class; mentioned during every lecture," the complaint states.
In October, K.R. says, Kubistant told her that the class was not for her. She says she complained to the college's administration, "providing an overview of the facts enumerated above," without result.
"Plaintiff complained about the discrimination, harassment and hostile environment created and perpetuated by Kubistant to Morin, College Department Chairperson," the complaint states. "Plaintiff asked Morin if Kubistant's class had ever been observed in the last seven (7) years; Morin refused to answer informing Plaintiff to contact legal counsel. Plaintiff asked Morin about the faculty handbook policy stating, 'faculty asking any students about personal sex is sex harassment;' again, Morin refused to answer, referring plaintiff to WNC legal counsel."
K.R. says she did so, and the college's attorney informed her that "a claim of sexual harassment could not be made since plaintiff, by signing the Acknowledgement, 'welcomed' whatever discrimination and/or harassment Kubistant was committing."
K.R. then withdrew from the class.
She seeks damages for a hostile and offensive work environment, conspiracy, Title IX violations and violation of equal protection. She is represented by Kenneth J. McKenna.