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CASE NAME
Young v. Colorado Department of Corrections et al I
Overview
Plaintiff, a former employee of the Colorado Department of Corrections, alleged 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
On March 11, 2024, the circuit court affirmed the district court's decision to dismiss the case for failure to bring a valid claim. The court found that Plaintiff did not offer enough facts to support his claim that the DEI training materials were so severe and pervasive "as to...alter the terms of employment for its employees and create an abusive" work environment. The court also found that Plaintiff did not allege that the training occurred more than once or that he was subjected to harassing conduct, ridicule, or insult from co-workers and supervisors as a result of the training. The court also affirmed the district court decision to dismiss the claim because Plaintiff lacked standing as a former employee of Defendant. Lastly, the court affirmed the district court's decision to dismiss the case without an opportunity for Plaintiff to amend the complaint since Plaintiff did not request the leave in his response to the motion to dismiss.
Court
Tenth Circuit
Status
Filed March 07, 2023 | Decided
As a result of the case being dismissed without leave to amend the complaint, Plaintiff opened a separate case (Young v. Colorado Department of Corrections et al. II) to continue challenging the DEI training.
Litigation History
Significance
This case demonstrates that diversity training alone is unlikely to create a hostile work environment under Title VII.