Joshua Young, a white corrections officer, attended a mandatory racial sensitivity training at the Colorado Department of Corrections. The training included a glossary defining “white exceptionalism” and “white fragility,” advice that leaders should let less powerful people speak first, and recommendations of videos about discriminatory housing and intersectionality. Young found the training offensive. He believed it created disturbing generalizations about the role of all white people in perpetuating the mistreatment of racial minorities. He quit four months later and sued.
This wasn’t Young’s first try. When Young first filed a hostile work environment claim in 2024, the Tenth Circuit dismissed it, holding that a single training session wasn’t enough to state the claim. But, the Tenth Circuit left a crack in the door: “[P]erhaps an ongoing, continuing commitment from Mr. Young’s supervisors to mandatory [equity, diversity, and inclusion] trainings with content similar to the one here may evolve into a plausible hostile workplace claim.” Young took the hint. He filed a new complaint adding five allegations: (1) the Department committed to continuing this type of training; (2) employees had to endorse the training’s race-based ideology; (3) supervisors were already acting on the training in disciplinary decisions; (4) the training compromised security because white guards might loosen restrictions to avoid racism accusations; and (5) the Department failed to investigate his allegations.
The district court dismissed with prejudice. Young appealed, arguing that the district court should have liberally construed his counsel-drafted complaint. The Tenth Circuit acknowledged a tension in its case law — some panels say only pro se pleadings get liberal construction, others say all complaints do. Assuming for argument’s sake that liberal construction applied, the panel nonetheless affirmed.
The Court held that Young failed to clear the “extremely high” bar for a hostile work environment claim. The workplace must be “permeated with discriminatory intimidation, ridicule, and insult” that alters employment conditions. More than a few isolated incidents are required.
The glossary allegations had already been rejected in the prior appeal. The recommendations of videos had been rejected too. The new allegations didn’t move the needle. Young speculated about future trainings, but he experienced only one session and quit four months later — fears about future programming don’t render a workplace overtly hostile in the interim. The training itself included admonitions that employees did not need to change their values or beliefs. Young alleged no negative feedback from supervisors, no discussion of the training, no one actually calling him a racist — just his suspicion that others viewed him that way. The single incident involving another officer of a different race who allegedly used a racism complaint to reverse discipline was unexplained: Young didn’t say whether the accusation was warranted, whether it occurred after the training, or how it affected his own work conditions. His claim that the training compromised security because white guards might loosen restrictions remained speculative. His allegation that he second-guessed his own decisions about using force and screening contraband showed only hesitation, not an alteration of job duties. And the Department’s failure to investigate, without demonstrable harm, left him no worse off than before he complained.
The Court also rejected Young’s constructive discharge claim, as it was entirely derivative of the failed hostile environment claim. Finally, the Court upheld dismissal with prejudice with prejudice, barring Young from continuing to attempt to litigate the issue. Young had filed four versions of the complaint across two actions and never explained how further amendment could cure the deficiencies.
The Court did not hold that DEI training can never create a hostile environment for white employees. It assumed for argument’s sake that such training could, in theory, cross the line. But Young’s allegations — a single training session, speculative fears about future sessions, no pattern of abuse, no concrete harm — did not get there.
Young v. Colo. Dep’t of Corr., 174 F.4th 1283 (10th Cir. May 11, 2026).