Did organization’s diversity training create hostile workplace for white staff member?

“I know Brett was really unhappy when he found out that he had to attend diversity, equity and inclusion training,” said Supervisor Nathan Hawkins, “but I’m surprised to hear he’s suing us for a hostile work environment because of the training.”

“I was surprised too,” said HR Director Carolyn McGill, “and disappointed. Most of the workers who went to the diversity training thought it was helpful. Brett, however, claims that the training was offensive to him as a white man. For instance, he says he was told during the training that race is an unscientific concept used to justify the oppression of minorities by white people.”

“That’s a pretty standard concept included in most diversity training programs,” said Nathan.

“You’re right,” said Carolyn. “However, Brett didn’t like some of the other theories featured in the training, including the idea that white exceptionalism is a belief by some white people that they aren’t racist even though they support the concept of white supremacy. And he wasn’t too keen on the discussion of white fragility, which describes the discomfort faced by a white person when confronted with information about racial injustice.”

“Brett might not have liked the ideas expressed during the training,” said Nathan, “but I’m not sure how he can claim the workplace became hostile to him as a result of the training. After all, the session lasted a couple of hours and that was the end of it.”

“Brett contends that the ideas advanced during the training spilled over into the workplace,” said Carolyn. “He alleges, for instance, that after the training, a Black coworker was disciplined less severely because of his race.”

“Brett needed to be watching his own P’s and Q’s,” said Nathan, “and not worrying about how his coworkers were being disciplined. Besides, how did the disciplining of a Black employee create a hostile work environment for Brett?”

“That’s a good question,” said Carolyn. “Brett also says he repeatedly complained that the diversity training was discriminatory against white people like him and that we failed to investigate his race-bias complaint.”

“There was nothing to investigate,” said Nathan. “Brett didn’t suffer any tangible changes in his work assignments following the training. He wasn’t disciplined for anything. Besides, employees who attended the training were told that they didn’t need to adjust their values and beliefs as a result of the training. We should challenge this lawsuit.”

Result: The company won. The court dismissed the case. The judge said the white staff member failed to show he endured a workplace that was severely and pervasively hostile to him as a result of the diversity training.

The training didn’t affect the white man’s terms and conditions of employment. He wasn’t disciplined after the training and he suffered no adverse employment actions. Without evidence that his working conditions had changed because of the training, his lawsuit lacked merit, decided the court.

While the white crew member also claimed that a Black coworker was disciplined less severely after the diversity training, he failed to show how that affected his own working conditions. And the company’s refusal to investigate his claim of race bias linked to the training also didn’t create a hostile workplace for him – there was nothing to investigate.

Cite:> Young v. Colorado Department of Corrections, U.S. Court of Appeals 10, No. 25-1068, 5/11/26.

(From the May 22, 2026, issue of HR Manager’s Legal Alert for Supervisors. To start your no-obligation trial subscription to the publication right now, please click here.)