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One DEI Training Wasn’t Enough to Create a Hostile Work Environment. Four Complaints Weren’t Enough Either.

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T

he bar for a hostile work environment claim is “extremely high.” A White correctional officer just found out ho

w

h

igh. TL;DR: The Tenth Circuit affirmed the dismissal with prejudice of a White correctional officer’s Title VII and Section 1981 hostile work environment claim, holding that a single DEI training and its aftermath didn’t come close to the “extremely high” standard required to render a workplace “permeated with discriminatory intimidation, ridicule,

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