This University Was Sued Over Antiracism Training—Here’s Why the Court Dismissed It

About a year ago, a federal judge greenlit the lawsuit of a former university professor who alleged that his employer created a racially hostile work environment through various discussions and initiatives focused on antiracism and racial justice.

In his complaint, the professor alleged that he had to attend conferences or trainings that framed racial issues in a way that negatively stereotyped white people. He pointed to meetings, personal interactions, and emails—including one from the Director of DEI that urged white employees to “feel terrible” about their “own internalized white supremacy.” Initially, the court ruled that the professor had pled enough facts for his lawsuit to move forward.

But filing a lawsuit is one thing—proving it is another. To win, the professor needed evidence that these incidents were so severe or pervasive that they created a hostile work environment. Without that, the university could argue for dismissal at the summary judgment stage.

And that’s exactly what happened.

What the Court Considered: 12 Incidents Over 3.5 Years

The court reviewed twelve incidents spanning over three-and-a-half years, including email exchanges, Zoom meetings, and professional development sessions discussing antiracist teaching practices. The legal test focused on whether these incidents, taken together, met the legal standard for workplace harassment.

• Severity: The court found that the professor may have found certain discussions uncomfortable, including ones in response to major societal events, like the murder of George Floyd. But, they were aimed to promote inclusivity. The court ruled that no rational person would see them as severe enough to create a hostile work environment.
• Pervasiveness: The judge determined that the incidents were too sporadic to meet the legal threshold for harassment. The events were spread out over months or even years, and many were not directed at the professor personally.
• Impact on Work Performance: The professor voluntarily engaged in many of the discussions and meetings. The court noted that his job responsibilities and benefits remained unchanged, meaning the incidents did not unreasonably interfere with his work.

Ultimately, while the professor may have found the discussions frustrating, they were part of broader workplace conversations about race, not targeted personal harassment. Hostile work environment claims dismissed.

Key Takeaways for Employers and HR Professionals

• Context Matters: The court emphasized that discussions about racial justice and antiracism—especially in response to significant societal events—are not inherently discriminatory. Employers should be aware of how employees experience these discussions but also recognize that not every complaint amounts to a legal violation.
• Voluntary Participation: The court noted that the professor voluntarily engaged in many of the discussions. Employers should consider making participation in DEI initiatives optional and clearly communicate this to employees.
• Constructive Engagement: While discussions about race can be uncomfortable, they should focus on fostering understanding rather than blaming or shaming any group. The court previously cautioned that “when employers talk about race—any race…with a constant drumbeat of essentialist, deterministic, and negative language, they risk liability under federal law.” Training sessions should be led by skilled facilitators to ensure they promote learning rather than alienation.

Final Thoughts

This case highlights an important balance for employers. Promoting diversity and inclusion is important, but workplace discussions should not single out or target employees based on any protected class. Employers should structure DEI programs in ways that encourage open dialogue without making employees feel blamed based on their protected class. By keeping training focused on education and inclusion, companies can foster a positive workplace culture while minimizing legal risks.