Discrimination Trainings Can Trigger Hostile Work Environment, Says Second Circuit

Mandatory discrimination trainings can provide the basis for a hostile work environment claim, the U.S. Court of Appeals for the Second Circuit recently held.

An educator employed by the New York City Department of Education (DOE), Leslie Chislett, a white female, supervised a diverse team as the executive director of the "AP for All" program.

Early on, there was racial tension on her team, and one subordinate accused her of microaggressions toward people of color. Several of her subordinates denounced her for allegedly "holding employees of color back" and, when she objected, she was accused of being "white and fragile."

When a new chancellor arrived at the DOE in 2018, racial conflict escalated, according to Chislett. An "equity agenda" was implemented to tackle racial and economic disparities, with mandatory implicit bias trainings for DOE staff.