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A federal lawsuit alleges a “human sexuality” class instructor at Western Nevada College in Carson City demanded that students masturbate and then write reports about their experiences or flunk his class.

The claim, reported by Oliver Darcy at CampusReform.org, was filed on behalf of Karen Royce against the college, instructor Tom Kubistant and the college president, Carol Lucey.

College spokesman Mark Ghan told WND the college investigated the complaint and found nothing to act on. The U.S. Department of Education also accessed the college’s report and found no grounds for action.

“The fact that the Department of Education declined to pursue the matter didn’t preclude the plaintiff from filing a lawsuit,” he told WND.

Ghan said he’s preparing a motion to dismiss, because the allegations are “embellished to such an extent they don’t reflect [what happened] in the classroom.”

He declined to be specific about what did happen but denied “absolutely” that students were told to perform sexually.

The federal lawsuit paints another picture. Royce, who says she experienced sexual abuse in the past, reported she felt “pure terror” when she was told the final term paper for students would be “A Sexual Case Study … You.”

The paper required students to detail how they lost their virginity, any sexual abuse they experienced, how they become sexually aroused, their masturbation habits and their promiscuous behaviors.

The complaint alleges Kubistant promised to deduct points from students’ grades should their papers not include the specifics.

The course description for the psychology department class said it covered “major topics in human sexuality such as gender, sexual anatomy, sexually-transmitted diseases, sexual response and disorders, sexual orientation, sexual coercion, and commercials sex.”

Royce, who wants to be a social worker, thought the class would be relevant to issues she might encounter in her career, the complaint explains.

“The first day of class was on August, 30, 2011. At the start of the class, Kubistant locked the door to the classroom. Kubistant intimidatingly informed the class that he unilaterally could kick any student out of his class at any time and give such student an ‘F.’ Kubistant touted himself to the class as a respected author and professional speaker. Kubistant demanded all students refer to him formally as ‘Doctor Kubistant.’ Although Kubistant has degrees in philosophy and counseling degree under the education heading, Kubistant informed the class he was a psychologist. Although it appears Kubistant possesses no valid license through the state of Nevada, Kubistant informed the class he was a ‘marriage and family therapist,’ a ‘professional sexologist,’ and a private practice sex therapist for over 20 years.”

The case notes that Kubistant had students sign an “acknowledgement” for the class, noting that the discussion could contain sexually explicit terms that may make students uncomfortable.

“Kubistant never once indicated that personal sexual disclosure would be a required part of the class experience,” the lawsuit alleges.

The instructor explained that the final paper would “require” discussion including: When did [I] begin early exploration of my genitals? … Did I experience a homosexual outing, phase, and what challenges were associated with that? Describe personal promiscuity behaviors; Do I cheat and how do I feel about it? … List all my sexual partners and describe the differences … Have I been raped or experienced any sexual coercion? What kind of fetishes do I have?

“Plaintiff felt pure terror,” the complaint said. “As a sexual abuse survivor, plaintiff was horrified at the thought of reliving the sexual abuse endured as a child.”

“The memories brought up simply by Kubistant’s requirement forced plaintiff to her bed crying for the entire evening,” the complaint said.

By the fourth class, “Kubistant then provided the class homework requiring students masturbate twice as much as they would normally do encouraging students to then disclose specifics in their journals again for Kubistant to read and review; specifics included arousal time and how long it actually took to achieve each orgasm,” the complaint continues.

When the plaintiff informed Kubstant she did not masturbate, “Kubistant became agitated and irritably informed plaintiff she must masturbate a minimum of three (3) times. Kubistant then angrily announced to the entire class they must masturbate if they intended to pass the class.”

Suspicious about his demands, Royce discussed them with other professors and with several doctors. She found no other class with such requirements, and the doctors were suspicious of Kubistant’s intentions.

Her complaints to college officials generated no results, and eventually she withdrew from the class, the complaint said.

As a result, she not only was deprived of taking a legitimate human sexuality class, she suffered “economic, extreme emotional distress, and loss of enjoyment of life and humiliation.”

The complaint seeks compensatory, general and special damages.

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