A student senator at the University of Southern California is the subject of a formal complaint seeking his removal from office for expressing his conservative opinions, such as inviting Milo Yiannopoulos to speak on campus and filming an event for Campus Reform.

Jacob Ellenhorn, who also serves as president of the USC College Republicans (CRs), received the complaint Monday afternoon, and immediately composed a statement denouncing the allegations as a politically motivated assault on his freedom of expression, sharing copies of both with Campus Reform.

The complaint against Ellenhorn, made by Program Board Executive Director Diana Jimenez, accuses him of three violations, all related to his political activities.

Jimenez begins by asserting that “there have been multiple articles written undermining the work of the Program Board Assemblies, especially the directors of our Women’s Student Assembly, [and] we as either elected or appointed members of the body have a responsibility to discuss and research any complaints our student body brings up.”

“If by ‘undermine’ she means speaking out against political bias, wasteful spending, and holding individuals accountable for their actions, then I guess I am guilty as charged,” Ellenhorn retorts, adding that since his election as a reform candidate, “I have been the target of vicious anti-Semitism and have been repeatedly targeted for my political beliefs” by what he dubs the “career student politicians.”

According to Jimenez, Ellenhorn “failed to uphold his duties” because he failed to schedule meetings between the Program Board and three Jewish students who had accused the head of the Women’s Assembly of student groups at USC of deliberately excluding Jewish speakers from a non-partisan event on campus. Ellenhorn, however, has a different perspective.

“She’s full of crap; I spoke to her in person and explained that I spoke to all of the girls, and they didn’t want to have a meeting with Program Board,” he told Campus Reform. “The accused students were calling the girls liars, and they didn’t feel comfortable speaking with the Program Board,” which was not sympathetic to their contentions.

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Jimenez next claims that Ellenhorn “has not behaved responsibility [sic],” because in his role as College Republicans president, “his involvement and programming has [sic] created a hostile environments [sic] for our USC student body, and has [sic] also violated our USC Principles of Community by bringing a speaker and moderating an event that blatantly perpetuates sexism.”

Here, she references two attachments to back up the charge: The Principles of Community, which disavow “racism, sexism, ageism, xenophobia, homophobia, gender identity, sexual orientation, ableism, and other forms of discrimination;” and a letter from Stephen D. Smith, an adjunct professor of religion and Executive Director of the USC Shoah Foundation–The Institute for Visual History and Education.

In the letter, dated October 7, 2015 and copied to the CR’s, Smith questions whether Milo Yiannopoulos, whom the CR’s had invited to speak on campus that evening, was “suitable for our campus,” given that “Yiannopoulos is known for his anti-feminist and more broadly misogynistic commentary.”

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Accusing him of failing in his duties as a senator for inviting a conservative speaker to campus in a separate capacity “shows Jimenez’s lack of interest in diversity of thought, and her propensity for silencing the opposition,” Ellenhorn responds. “Jimenez is clearly jealous of the fact that the events I put on as President of the College Republicans received far more attention than any of hers.”

The third violation Ellenhorn is accused of also concerns a Campus Reform article, but in this case, he is charged with failing to secure permission before filming the “Consent Carnival” that was held on campus in January by several student groups.

The complaint specifies that university rules require approval “for any filming required as part of an event (including footage for use on YouTube, Facebook, and other online platforms).”

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Insofar as Ellenhorn’s filming was not “required as part of an event,” but was rather the action of a private student documenting an open event, and was neither shared with the press nor posted online in any form, Ellenhorn dismisses the validity of that complaint out of hand, calling it an attack on freedom of the press.

Jimenez declined to comment for this story, saying she has reached out to Ellenhorn about setting up a meeting to discuss their differences,” but he has chosen not to have an in-person dialogue.”

Ellenhorn, for his part, believes that with her complaint, “Jimenez has shown blatant disregard for issues of free speech and freedom of expression,” adding that “instead of triumphing difference of opinion, Jimenez has decided to join the legions of vapid social justice warriors in their never[-]ending war on words, opinions, and the truth.”

“There’s three more weeks left in the Senate term, and she’s trying to come at me because she wants to get at my legacy in Senate,” Ellenhorn told Campus Reform. “She can try to silence me, but she’s not going to win. I’m right and she’s wrong, and I guess we’ll just have to let the court of public opinion decide.”

UPDATE: "I think the big picture is that here's a student who is simply trying to contribute to the marketplace of ideas on campus, and no his peers are trying to silence him for taking those actions," David Hacker, director of the Center for Academic Freedom at Alliance Defending Freedom (ADF), told Campus Reform. "That's not the marketplace of ideas; that's an indication of censorship and students being unwilling to hear another point of view."

Follow the author of this article on Twitter: @FrickePete