Affidavit of Thomas Brown

"[Ward] Churchill fabricated all of the central details of his [Mandan Indian] genocide story. Churchill also falsified the sources he cites in support of his genocide charges, sources which say the opposite of what Churchill attributes to them. Moreover, we must conclude that falsification and fabrication are habitual with Churchill. This essay has analyzed not much more than three cumulative pages of Churchill’s writing, drawn from across six different essays. (Since Churchill published his second version at least twice, this adds up to at least seven different publications.) Within those few pages, Churchill has committed multiple counts of research misconduct—specifically, fabrication and falsification."---Professor Thomas Brown

Professor Thomas Brown, who is currently a professor of sociology at Northeast Lakeview College in Live Oak, Texas, exposed the former University of Colorado (Boulder) professor Ward Churchill in a 2006 article published in Plagiary titled "Did the U.S. Army Distribute Smallpox Blankets to Indians? Fabrication and Falsification in Ward Churchill’s Genocide Rhetoric."

Professor Brown observes in a recent article titled "Truthiness v. Scholarship: Ward Churchill’s Day in Court" (4-6-09):

Churchill has since abandoned all of the fabricated aspects of his [Mandan genocide] story, while simultaneously claming that he did not fabricate it, because he still feels in his gut that the story is correct.

Now Professor Brown's affidavit about Ward Churchill's dishonest scholarship accompanies the University of Colorado's May 20, 2009 Brief in opposition to Ward Churchill's Motion for Reinstatement [Hat/Tip Mr. Paine of PirateBallerina]:

The Affiant, Thomas Brown, deposes and states:

1. I am over 18 years of age and understand the obligations of oath. I have personal knowledge of the matters I will describe in this affidavit.

2. I was assisted by Patrick O’Rourke of the Office of University Counsel in preparing the form only of this affidavit. The statements it contains, however, are my own; and I have given them voluntarily. I have not been pressured by the University to state any opinions that I do not honestly hold.

3. Reinstating Ward Churchill to his position at CU would have a “chilling effect” on academic freedom of speech. I know from personal experience that Mr. Churchill is a staunch opponent of other people’s free speech rights.

4. Mr. Churchill has a long history of aggressive, anti-collegial behavior towards academics who dare disagree with his opinions. Mr. Churchill has repeatedly attacked scholars who dare disagree with him by filing spurious misconduct complaints, by labeling them as “Nazis”, and by other types of ad hominem attacks, threats and intimidation.

5. If you decide to reinstate Churchill to his former position at CU, many people will mistakenly assume that your court has exonerated Churchill on the charges of research misconduct. This will give Churchill increased stature in the research community. Based on Churchill’s past habits, the results are predictable -- Churchill will use the bully pulpit you give him to intimidate and silence scholars who disagree with him.

6. After I posted a brief expose of Churchill’s fabrications surrounding the 1837 smallpox epidemic on my web page, he filed a spurious research misconduct complaint with my university. He concluded his complaint by demanding that my university formally reprimand me, require me to retract my research and apologize to Churchill, and remove my essay from my faculty web page. Thus Churchill launched an unabashed assault on my academic freedom of speech, and attempted to exercise prior restraint on my unpublished research.

7. Should you decide to return Mr. Churchill to his former position, CU will be restrained from sanctioning him for future misconduct, given Mr. Lane’s promise to file a retaliation lawsuit. In reinstating Churchill, you will give him free rein to continue his habits of fabricating and falsifying the scholarly record, and of attacking the free speech rights of junior scholars.