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.