A single mandatory DEI training did not plausibly create a hostile work environment, the Tenth Circuit recently ruled. Its decision in Young v. Colorado Department of Corrections affirmed the dismissal of Title VII and Section 1981 claims.
The plaintiff employee alleged that the training’s focus on systemic racism was discriminatory toward white employees, but the court held that the complaint failed to allege conduct that was sufficiently severe or pervasive. The court emphasized that a single training event is unlikely to create liability without additional facts showing ongoing conduct or material workplace impact. At the same time, DEI training could still create liability risk for an employer if it is paired with repeated messaging or adverse employment consequences.
A court in a jurisdiction that does not use Title VII’s “severe or pervasive” standard could reach a different result on a similar claim.
Members of the Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, can read more here.