Unreasonable, Uninformed Objection to DEI Initiative Does Not Protect Employee from Termination

In a victory for employers committed to diversity, equity, and inclusion, the U.S. Court of Appeals for the Seventh Circuit rejected an employee’s claim that he suffered a retaliatory termination after refusing to complete unconscious bias training—training designed to improve workplace inclusiveness.

The case, Vavra v. Honeywell Int’l, Inc., considered whether the employee’s objection to mandatory DEI training was objectively reasonable, a key requirement for protection under Title VII of the Civil Rights Act of 1964. The employee refused to complete the training based on his belief that it villainized his white colleagues and turned non-white colleagues into victims. But, as the Court noted, the employee never actually viewed the training and formed his belief based on pure speculation and despite assurances to the contrary from his supervisor. On these facts, the Seventh Circuit decided against the employee, concluding that refusing the training was not objectively reasonable or protected by Title VII.

As employers embrace implicit bias training and other DEI initiatives in the workplace, Vavra offers a roadmap for pursuing employee compliance through “earnest[] and repeated[]” follow-up. Likewise, Vavra confirms that employers, at least those within the Seventh Circuit (Illinois, Indiana, and Wisconsin), are not without recourse when faced with employees making unreasonable, uninformed objections to those initiatives.