On June 24, 2026, Johnson County Community College issued its final outcome letter in the case of a longtime employee who raised concerns about indoor air quality, requested ADA accommodations, and filed a formal retaliation complaint. The college says it retained an "independent investigator" to conduct a "neutral fact-finding investigation." That investigator's report went to JCCC's own Audit & Advisory Services. The outcome cleared every respondent on every ground: no retaliation, no failure to accommodate, no constructive termination.
Set aside, for a moment, whether that specific conclusion was right. The more important question — the one that should outlast this single case — is whether an investigation selected, paid for, and received exclusively by the institution accused of wrongdoing can ever be fairly called neutral. We don't think it can, and we think the public is being misled by professional marketing that says otherwise.
What the Complaint Was About
The underlying record involves protected activity across several legal frameworks: ADA and Section 504 accommodation requests, FMLA-related leave issues, Kansas Open Records Act requests about historical water intrusion and mold, OSHA-adjacent safety reporting on indoor air quality, First Amendment-protected speech, and whistleblower retaliation.
The employee's documented statement of facts lays out a pattern: delay in addressing the air-quality concerns, suppression of internal discussion of the issue, administrative leave, exclusion from campus, stripped responsibilities, denial of a remote-work arrangement that had previously worked without incident, an accelerated negative performance review issued shortly after her protected activity — a review lacking contemporaneous documentation for its key criticisms — and, after she made a final, explicit demand for an effective accommodation and the college did nothing in response, an attempt to recast her eventual separation as a voluntary resignation.
The final outcome letter does not appear to grapple with the timing between her protected activity and the sudden negative review. It does not explain how an institution that took no action at all in response to a final accommodation demand can simultaneously argue the conditions it created were not intolerable. The letter cites the correct legal standard for constructive termination. Whether that standard was actually applied to the facts in the record — including the demand the college ignored — is something the public has no way to check, because the report itself was never made public and the complainant was never given a real chance to contest it before the findings were finalized.
Who Investigated This, and How She Markets That Role
The investigator was Lara Pabst, also known professionally as Lara Krigel Pabst, a shareholder at Krigel Nugent + Moore, P.C. in Overland Park, Kansas. Her firm's own biography says she "acts as a third-party investigator for businesses and educational institutions." Krigel Nugent + Moore's workplace-investigations marketing calls these services "unbiased, third-party investigations," tells employers to hire a "neutral third-party," and advertises the service to companies, school districts, colleges, and universities.
That marketing is fair game for scrutiny, because it's the exact promise complainants are told to rely on. When an institution says a "neutral" investigator will look into a civil rights complaint, and that representation traces straight back to the investigator's own website describing her services as "unbiased" and "third-party," the public is entitled to ask what, structurally, makes any of that true.
We are not claiming Lara Pabst lied or knew her conclusions were wrong. We have no window into her state of mind, and that is not our argument. Our argument is structural, and it does not require bad faith to be true: an investigation funded by one side, reported only to that side, with no mechanism for the other side to test or rebut it, is not neutral in any meaningful sense — no matter who conducts it or how skilled they are.
The Structure Speaks for Itself
Strip the names away and look at the mechanics:
The Institution-Paid Investigation Model
- The institution facing the complaint picks the investigator.
- The institution facing the complaint pays the investigator.
- The report goes to the institution — here, to JCCC's own Audit & Advisory Services — not to any independent body.
- The complainant never sees a version of the report she can meaningfully challenge before it becomes final.
- The institution then deploys the "neutral" findings wherever it needs them: closing the internal complaint, fighting an unemployment claim, answering a federal agency, defending a lawsuit.
This structure produces a predictable result on its own, without anyone needing to act dishonestly. The institution has direct financial and reputational exposure if the investigator finds against it. The investigator's livelihood depends on a client base of institutions that hire investigators like her again and again. None of that requires a single corrupt act. It only requires that the two parties capable of catching a one-sided result — the complainant and the public — are locked out of the process entirely.
This is not an accusation that Lara Pabst's findings here were dishonest. It is an accusation that the word "neutral," attached to a process built this way, should not survive public scrutiny — and that the bar associations licensing the attorneys who run these investigations need to ask whether the label matches the structure.
Why This Should Matter to People Who've Never Heard of This Case
Public colleges run on tax dollars and answer to the public. When an employee raises a safety concern that could affect students and coworkers — not just herself — and the institution responds by hiring and paying its own investigator, the "no findings" result becomes permanent ammunition. It gets cited to deny unemployment benefits, to tell a federal civil rights agency there's nothing here, and to defend the institution in court.
If the model itself is built to produce institution-favorable outcomes, that's true everywhere this model is used — not just at this college, and not just in this case. Every employee at every public institution that hires its own "neutral" investigator should know what that label actually means in practice.
What Needs to Happen
The Kansas Office of the Disciplinary Administrator should examine whether marketing language like "unbiased, third-party investigations" — attached to engagements funded solely by one party — holds up under KRPC 7.1's bar on misleading communications about legal services and KRPC 8.4's conduct rules. We're not asserting a violation has been proven. We're asserting the question is squarely theirs to answer, and they should answer it.
Public institutions should stop pretending institution-funded investigations are neutral and start acting like it: mutual selection of investigators, neutral panels or government resources instead of counsel paid solely by the accused institution, and mandatory disclosure of compensation and prior relationships.
Complainants facing this model should demand discovery into the investigator's engagement letter, compensation, prior relationship with the institution, and instructions given — and should refuse to let an institution-selected, institution-funded report claim the deference owed to genuinely independent fact-finding.
The public — anyone who works for a public institution, has a relative who does, or pays the taxes that fund one — has every right to know whether "neutral investigation" describes a real process or just a label.
Conclusion
We are not saying Lara Pabst or Krigel Nugent + Moore acted dishonestly in this matter. We are saying this: an institution facing a serious civil rights complaint hired and paid its own investigator, that investigator reported only to the institution, the complainant never got a real chance to test the findings, and the result was a clean sweep for the institution on every contested issue — including an unanswered final accommodation demand that any genuinely adversarial process would have had to confront head-on.
Those facts alone justify public concern about the model, regardless of anyone's individual motives. "Neutral" should describe a structure that can be tested — mutual selection, transparent pay, a real chance for the other side to respond. Where that structure is missing, the label doesn't earn the trust it asks for, and the institutions and bar authorities responsible for oversight owe the public an answer for why it's used anyway.
This is a matter of public concern: how publicly funded institutions investigate their own employees' civil rights complaints, and whether the attorneys hired to do it are describing their services honestly. The public is entitled to ask. The public is entitled to answers.