The definitions in our glossary are primarily sourced from Nolo’s Plain-English Law Dictionary and Cornell Law School’s Legal Information Institute. We have made slight modifications where needed for brevity and to better tailor the definitions to the specific needs of users of this website. For more detailed explanations of the terms, users are encouraged to review the definitions on these websites or conduct their own independent research.
CASE NAME
Young v. Colorado Department of Corrections et al
Overview
Plaintiff, a former employee of the Colorado Department of Corrections, alleges that his employer created a racially hostile work environment based on mandatory DEI training that allegedly promoted offensive and racist generalizations about white people.
Details
The court (affirmed on appeal by the Tenth Circuit Court of Appeals) dismissed Plaintiff's claim, finding that the training materials were not sufficiently severe or pervasive to create a hostile work environment under Title VII. The training did not occur more than once, and there was no race-based harassing behavior from Plaintiff's coworkers.
However, Plaintiff subsequently filed a motion to reopen the case so that he could continue to litigate a hostile work environment claim under section 1981 and a constructive discharge claim. The court granted this motion and the case is ongoing. Defendant has filed a motion to dismiss the latest complaint, arguing that Plaintiff may have misunderstood the DEI training's message or may have a disagreement with its content, but that he has not suffered workplace discrimination.
Court
U.S. District Court, District of Colorado
Status
Filed June 30, 2023 | Ongoing
Significance
This case indicates that diversity training alone is unlikely to create a hostile work environment under Title VII.