Comparisons are not available for terms that contain or interact with random factors. Nesting is a form of interaction. Suppose the model contains A B C A*B, where both A and C are random, and B is fixed. Because A*B is a term in the model, no multiple comparison results for B are available even though B is a fixed factor. However, if the model does not include A*B, multiple comparison results are available for B.
There is a special case for a balanced design that has two factors. Suppose the model contains A B A*B, where A is random, and B is fixed. Even though A*B is in the model, you can perform multiple comparisons for B.