Matt Barter

January 20, 2025

Dr. Jennifer Browne

Director of Student Life and Conduct Officer

Memorial University 

Via email: jbrowne@mun.ca

Dear Dr. Browne,

Re: Your January 20 Reply

Your response to my January 14 letter, claiming the university cannot comment on how my case compares to others, is an outright falsehood. The Horwood report itself explicitly references multiple past protests, including the Gary Kachanoski pink slip incident, the storming of a Board of Regents meeting, and a protest on Grenfell Campus. Your office has demonstrated its ability to comment on such cases —yet now you feign ignorance.

For reference:

     1.    May 10, 2017 – Dr. Kachanoski was blocked from entering a Senate meeting by students holding a large pink slip sign addressed to him by name, declaring, “You’re fired.”

     2.    May 11, 2017 – Students, including myself, stormed a Board of Regents meeting, shouting and physically hitting walls and doors.

     3.    April 22, 2016 – Grenfell Campus students interrupted Finance Minister Cathy Bennett’s presentation by chanting and displaying a banner that obscured her presentation screen.

During the investigation into my case, Kimberley Horwood specifically inquired about these incidents. Your office confirmed that no Student Code of Conduct investigations or sanctions resulted from them, explaining that the Code is “complaint-driven.” If no complaint is made, no investigation occurs. Horwood rightly criticized this inconsistency, stating:

“This is concerning because the Student Code of Conduct should be uniformly applied to all students.”

She further noted that it was reasonable for me to rely on past incidents as precedent, given the lack of clarity about acceptable conduct under the Code.

Despite this precedent and your office’s history of commenting on prior protests, you now refuse to explain your inaction regarding recent protests:

     1.    December 2, 2022 – Students confronted Vianne Timmons with a large pink slip sign and nearly wrapped her in it.

     2.    May 30, 2024 – MUNSU’s Nicolas Keough held up a sign reading “MUN SUPPORTS ISRAEL’S GENOCIDE IN GAZA” and shouted, “Free Palestine!” in President Neil Bose’s face during a Convocation ceremony.

     3.    June 7, 2024 – Students began a 45-day occupation of the Arts and Administration Building in solidarity with Palestine. On July 5, 2024, the university involved the Royal Newfoundland Constabulary, who issued petty trespass notices and arrested students who refused to vacate the premises.

     4.    June 17, 2024 – A student displayed a sign reading, “NEIL BOSE YOU HAVE BLOOD ON YOUR HANDS.”

     5.    January 13, 2025 – MUNSU publicly criticized both finalist candidates for the Provost position. Through posts on various social media platforms, including X (formerly Twitter), MUNSU’s Executive Committee, who are also MUN students, stated that they could not endorse or support either candidate. They accused both individuals of supporting policies harmful to the university and failing to show adequate respect for the student body. MUNSU shared a letter addressed to the Provost Search Committee that contained personal critiques of the candidates, including one aimed at Dr. Lokash, alleging a lack of understanding of the provincial government’s funding obligations and accusing her of belittling a Palestinian student. They included the candidates’ names and photographs in their public materials.

Horwood recommended that the university adopt a policy of proactively investigating publicized protests to ensure fair enforcement of the Code. This has yet to be implemented. 

On another note, General Counsel Scott Worsfold’s claim that students involved in the 1972 Arts and Administration Building occupation were reprimanded is categorically false. Those students negotiated a non-penalty agreement as part of resolving the occupation. Worsfold’s refusal to correct this falsehood only further erodes the university’s credibility.

The pattern of falsehoods and selective enforcement is undeniable. A deliberate decision not to act on certain protests is still a decision. Your failure to apply the Student Code of Conduct consistently exposes the targeted and punitive nature of your actions against me. You weaponized the Code to suppress my peaceful protest and journalistic work, marking a disgraceful chapter in Memorial’s history.

In December 2021, under the disgraced leadership of Vianne Timmons, I was unjustly banned from campus, placed on probation, and assigned an anti-bullying seminar for exercising my right to protest. These actions were not only punitive but also a direct attack on free expression, journalism, and democracy. I had no choice but to take this matter to the Supreme Court of Newfoundland and Labrador, where the university’s actions will ultimately be exposed for what they are: a targeted smear campaign.

Former Provost and Vice-President Noreen Golfman–who had herself been a subject of my past protests–called your actions against me a “real overreach.” Golfman also disputed the characterization of me deliberately targeting women. “I just don’t buy it,” she said, adding she never once felt that my protests against her were personal, nor did they have sexist or misogynistic elements. “He was a kind of [an] equal opportunity activist as far as I was concerned,” she said. When asked about what the university’s handling of my case reflects regarding the broader governance crisis at Memorial, Golfman stated, “it speaks to a kind of imperiousness.” Many within the university have observed a “strong force” of administrative solidarity, making Golfman’s decision to break ranks and criticize your actions particularly significant. 

The Director of Toronto Metropolitan University’s Centre for Free Expression, Jim Turk, called the allegation that I “crossed a line” when I protested Timmons “bullshit.” He said that Timmons’ allegation that my protest against her was personal does not hold up to scrutiny as I had repeatedly criticized the university administration’s fiscal policies, including tuition fee increases, under Timmons’ leadership and also under the leadership of President Gary Kachanoski. Turk said, “Our Charter claims one of the fundamental freedoms in Canada is freedom of expression, so you certainly wouldn’t want a university being a model for more repression of freedom of expression than is a general citizen’s right on a street corner in the town in which the university is located.”

Canadian Civil Liberties Association Director of Fundamental Freedoms, Cara Zwibel, stated that your interim sanctions against me were “extreme” and that there’s a “decent argument” you violated my Charter rights. She said that my action was “a relatively low-key way of protesting.”

As a journalist, I have published over 600 articles uncovering Memorial’s financial mismanagement, including lavish executive spending and misuse of public funds. My reporting predated many of the findings in the Auditor General’s report. It is no coincidence that my peaceful protest and investigative journalism—shining a light on Memorial’s financial mismanagement—made me a target.

Your role as Conduct Officer during my case was a glaring conflict of interest. Your alignment with Vianne Timmons and your imposition of a harsh campus ban prevented any impartial review of my actions. This constitutes unethical behavior and a breach of the Respectful Learning Environment Policy, which guarantees all students fair treatment. Your behaviour is inappropriate and unethical. All students are entitled to a university experience free from inappropriate, unfair and objective conduct by Memorial employees and officers, as per the ‘Respectful Learning Environment Policy’ process. Under that procedure, a Memorial employee or officer who conducts themselves in such a manner towards a student will be subject to an investigation by the appropriate department and may face sanctions accordingly. 

That process recommends that the student approach the offending employee informally before commencing a formal complaint. Please take this as informal notice that I consider your decision to prosecute me under the Student Code of Conduct as a bad faith action and worthy of investigation. I also consider your decisions since then not to prosecute similar protests as further evidence that it was targeted. 

As a resolution, I demand a written public apology from you and your office by Wednesday, January 22, 2025. Should you fail to comply, I will escalate this matter by filing a formal complaint with the Director of Support Services in the Office of Student Life.

Let me remind you that Memorial University belongs to all Newfoundlanders and Labradorians—not to a self-serving administration that manipulates policies to silence dissent. Your conduct is an affront to the principles of transparency, accountability, and fairness.

Sincerely,

Matt Barter