IMPORTANT RECORD CITeS

page 9 paragraph 1

In the 2022-2023 academic year, there were a number of disturbing events on OSU’s campus.

First, two female students who wore head scarfs were assaulted by two masked men while

walking back to their dormitory from the library. The assailants reportedly told the students to

“go back to their own country” and called them “terrorists.” Second, misogynist slogans were

spray painted outside the building where the Department of Women’s, Gender and Sexuality

Studies is located. Third, anti-Semitic slogans were spray painted outside the campus chapter of

Hillel. Fourth, two men were caught on surveillance video hanging a noose inside the Student

Union. In addition, flyers bearing a variety of offensive slogans aimed at a variety of groups

were distributed on campus by students and non-students alike.

page 9 paragraph 2

The aforementioned incidents prompted the OSU student government to organize a campus event

called Unity Fest to promote campus-wide unity regardless of nationality, religion, race, sex, or

sexual orientation. Unity Fest was held in April 2023 and was open to OSU employees and to

students, as well as, to the local community. OSU President Jackie Zambrano gave the student

government permission to host the event and recommended the inclusion of professors, including,

inter alia, DeNolf, who was well known as a popular and dynamic lecturer who liked to write

poetry about social issues.

Page 9 paragraph 3

DeNolf, who was very concerned and distraught by events that had occurred on campus, was

excited about the festival. DeNolf asked several of his colleagues at OSU, including Professor

Bronner, for suggestions as to which of his poems he should recite. DeNolf did so because several

professors were familiar with his work. The consensus was that DeNolf should present a poem

he had written about the Policy entitled “Imagine a Level Playing Field.” The poem followed the

lyrics and beat of John Lennon’s song entitled “Imagine.” It addressed society’s use of

affirmative action to supposedly level the playing field for all. The poem’s theme was that to

truly create a world that was fair for all society must forgo affirmative action. Before presenting

the poem, which he sang, while playing an acoustic guitar, DeNolf blasted “the powers that be”

and asserted that “affirmative action is inconsistent with true equality.” He called for “an end to

laws that favor people based on immutable characteristics” and called for “students to rise up and

challenge inequality whatever form it takes and wherever they find it—including at OSU.”

Page 10 paragraph 2

The next day, videos of DeNolf’s performance went “viral” on several social media sites. A

blogger named “Action Jackson” live-streamed the performance on her Facebook page, which

was viewed by more than 1.5 million followers. Students around the nation and prominent

activists for men’s rights across the country praised DeNolf for his courage, strength, and

message. After Unity Fest, DeNolf did several radio interviews, each time being introduced as a

lecturer at OSU. DeNolf accepted invitations to appear on both the “Rachel Maddow Show” and

“Fox and Friends,” where he discussed affirmative action. DeNolf, who identified as “a

progressive in most every way,” denied that he had a political agenda or was a male supremacist.

Rather, he asserted, “I believe men and women are equal in every way, I simply want everyone

to be treated equally – a level playing field.” DeNolf was invited to attend various conservative

conventions, as well as participate in a symposium sponsored by Students for Fair Admissions.

He turned these invitations down; however, he did agree to give a TED Talk and he participated

in a series of collegial debates on college campuses with supporters of affirmative action.

Page 10 paragraph 3

DeNolf’s message was not well received by everyone, especially by many people with

connections to OSU and/or the School. The offices of OSU President Zambrano and the College

of the Liberal Arts were inundated with phone calls, emails, and letters, the overwhelming

majority of which disapproved of DeNolf’s message and the manner in which he continued to

criticize the School. A great many of these messages came from the parents of students, donors,

and alumni. Several elected officials who called upon OSU to take action in defense of the female

graduate students at the School—many of whom had been “trolled” on social media and had been

labeled “Affirmative Action Babies!” By and large, the persons who contacted OSU were upset

that the university, by virtue of the fact that it employed DeNolf, appeared to endorse his point

of view.

Page 11 paragraph 1

alumni donations, and how it would affect OSU’s highly ranked athletic programs, especially

since recruiting future student-athletes was dependent on these donations. Vice-President Finn

informed President Zambrano and Chairman Brewer that total applications and those filed by

women were down by 20% and 33% respectively. A second meeting, on May 8, 2023, was

convened. This time President Zambrano and Vice President Finn met with the full board.10

Page 11 paragraph 2

On May 27, 2023, President Zambrano spoke with OSU Provost Dr. Carolina Dykes and the

Dean of the College of Liberal Arts Dr. Sean Ignatuk. They agreed that DeNolf was to be fired

and that Dean Ignatuk, OSU’s legendary undergraduate moot court coach, would do the firing.

On May 29, 2023, Dean Ignatuk, whose office had to bring in extra staff from a different office

to handle all the complaints about DeNolf, met with and informed DeNolf that his contract would

not be renewed – thus firing him. Dean Ignatuk did so after keeping DeNolf waiting in his outside

office for 45 minutes. The non-renewal, which was opposed by Professor Bronner, was

announced on OSU’s website. President Zambrano contacted all donors, parents of current

students, and alumni to inform them of OSU’s actions and to apologize for any pain that they

may have been subject to or any offense that they had taken.

Page 8 paragraph 2

DeNolf taught two courses per term. He was rewarded with extra pay if he served as a faculty

advisor to student groups. To that end, DeNolf assisted with the Department’s Mock Trial

Program. While presenting at conferences was not a requirement of his employment, OSU

encouraged its lecturers, full and part-time alike, to present papers at conferences and at other

academic settings. In addition, OSU encouraged its lecturers to publish their work in academic or

commercial journals, and on-line public platforms, such as newspapers and professional websites.

During his employment, DeNolf was eligible for travel support from OSU, as well as for a small

stipend to cover costs related to research. The faculty at OSU is not unionized.