In addition to getting his job back, Hussein S. Hussein's lawsuit seeks an injunction that would order retroactive pay of his $98,000 annual salary with full benefits. It also seeks to rescind UNR President Milton Glick's order banning him from campus when he fired him April 11.
"The instant termination is but the latest in a six-year campaign to destroy Dr. Hussein and his career," according to the lawsuit filed Tuesday in Washoe County District Court.
"Dr. Hussein reported affirmative action violations and animal abuse at UNR and has ever since been the target of punishment by those he exposed," including Glick, the suit said.
Hussein, an internationally renowned animal nutritionist, began working in 1997 as an associate professor in the Department of Animal Biotechnology in UNR's College of Agriculture, Biotechnology and Natural Resources.
A federal investigation sparked by Hussein's complaints about UNR's animal farm and labs resulted in the U.S. Department of Agriculture citing the university for 46 violations of federal animal welfare regulations from May 2004 to March 2005.
The violations included repeatedly leaving research pigs without adequate water and housing, frequent poor sanitation and lack of veterinary care. The school agreed to pay an $11,400 fine.
Glick fired Hussein after a disciplinary hearing based on claims that Hussein plagiarized his graduate students' work and misrepresented money given to support his research to improve his laboratory instead of sharing it with the university to pay for overhead costs.
John Albrecht, a lawyer for the Nevada System of Higher Education representing UNR and Glick, said he has filed a motion opposing a temporary restraining order.
"The university will vigorously resist any legal action that would reverse Dr. Hussein's termination," he said Wednesday.
Hussein also has appealed to the state Board of Regents, which is expected to consider his termination at its June 12 meeting.
In addition to economic hardship, Hussein said in an affidavit attached to his lawsuit that he is "suffering from substantial emotional distress and mental anguish, not to mention harm to my reputation, humiliation, grief and loss of enjoyment of life."
Prior to making the complaints to USDA, Hussein had received high marks on his annual performance evaluations, Hussein's Reno lawyer Jeffrey Dickerson said.
"When he exposed animal abuse and corrupt hiring practices, things changed," the lawsuit said.
Dickerson said Glick's formal letter of termination to Hussein did not cite any rationale for banning him from campus.
Hussein "has never presented any danger to anyone. He is a peaceful man. So, Glick's ban from campus order must be purely designed to humiliate" Hussein, the lawsuit said.
Glick said in the April 11 termination letter that he had concluded Hussein was dishonest and guilty of incompetence or inefficiency in performing his duties as well as professional conduct which was harmful or adverse to the efficiency of his administrative unit.
"Your acts in these areas demonstrate serious misconduct over many years," Glick wrote.
Glick's decision to fire Hussein was contrary to the findings of Peter Breen, a former Washoe District Court judge who served as special hearing officer in the disciplinary hearing.
In a 28-page report, Breen found Hussein concealed the contractual nature of three research projects, preventing the university from collecting $377,000, but that his actions did not merit being fired. Breen's report was made to a four-member faculty committee, which made a disciplinary recommendation to Glick.
"President Glick ignored three of four hearing committee members recommendation not to terminate Dr. Hussein," the lawsuit said.
Hussein also faced a disciplinary hearing in 2005 on a charge that he violated university regulations by hiring a Reno veterinarian to examine research pigs he thought were being abused. That charge was later dismissed.
The Nevada State personnel rules, backed up by the Nevada judicial system continually attacks (and fires) the people who point out the corruption and waste of the State government instead of getting rid of the people who create it. The old "treat the symptom rather than the problem" syndrome.
WAKE UP NEVADA!