• Skip to primary navigation
  • Skip to main content

HRMorning

  • FREE RESOURCES
  • PREMIUM CONTENT
  • HR DEEP DIVES
  • PODCASTS
    • VOICES OF HR
    • WOMEN’S LEADERSHIP TODAY
  • LOGIN
  • SIGN UP FREE
  • Employment Law
  • Benefits
  • Recruiting
  • HR Technology
  • Payroll
  • Management
  • Women’s Leadership
  • More
    • Talent Management
    • Performance Management
    • Leadership & Strategy
    • Compensation
    • Policy & Procedures
    • Wellness
    • Staff Departure
    • HR Career & Self-Care
    • Health Care
    • Retirement Plans
  • Employment Law

‘Woke’ training? Employee demands religious accommodation

Carol Warner
By: Carol Warner
  • Share on

About the Author

For nearly two decades, Carol Warner has analyzed the legal and financial realities behind workplace decisions, covering employment law, benefits, payroll and HR technology. She translates complex legal updates, regulatory shifts and vendor claims into plain language that HR teams can act on. Her focus is simple: What does this mean for employers, and what should they do next? Connect with her on LinkedIn.

Show Less
Last Updated: January 27, 2023
3 minute engagement
Employee objects to training on religious grounds

Picture this: You make arrangements for new employee training that aligns with your company’s diversity, equity and inclusion (DEI) initiatives. But one employee objects to the “woke” training and asks for an exemption on religious grounds.

How do you properly balance the company’s DEI goals with an employee’s request for religious accommodation? That was one company’s dilemma.

Conservative employee opposes ‘woke’ training: 2 reasons

Meet Joseph Norgren. He’s a Christian who, as of 2020, worked for his employer for 27 years. That year, he was preparing for retirement.

In August 2020, Norgren and all of his colleagues were notified that they would have to complete computer-based training on anti-racism and gender identity. Specifically, the sessions were titled “How to be Anti-Racist” and “Understanding Gender Identity and Expression: Moving Beyond the Binary.”

Norgren opposed the training sessions. First, he compared the anti-racism session to the “woke” Critical Race Theory,  which he claimed violated “the traditional view of equality under Title VII.”

Second, he said he also opposed gender identity session because the concept of nonbinary gender is “contrary to his sincerely held religious belief.”

Meanwhile, Norgren continued his plans for his then-upcoming retirement. On Oct. 6, 2020, he sent an email to HR confirming his retirement date, which was Jan. 6, 2021.

Nearly three weeks later, Norgren sought a religious exemption to be excused from the gender identity training. As an FYI, he did not specifically ask for a separate exemption that would also excuse him from the anti-racist training.

The company denied his request for the religious exemption. As a result, Norgren then emailed his resignation, saying he felt “forced to prematurely separate” from his job.

He also filed a complaint with the Equal Employment Opportunity Commission (EEOC), alleging discrimination, retaliation and constructive discharge.

The EEOC issued a right-to-sue letter, and Norgren filed a lawsuit alleging he was constructively discharged. The suit also included claims of race and religious discrimination and retaliation in violation of Title VII.

To state valid race and religious discrimination claims, Norgren had to show, among other things, that he suffered an adverse employment action. He did not do so, the court said.

Was it race discrimination?

To support his race discrimination claim, Norgren said he suffered an adverse employment action by being constructively discharged due to the hostile environment caused by his opposition to the anti-racism training.

But the court was not swayed.

In the court’s view, requiring “all employees to undergo diversity training does not amount to abusive working conditions, and does not plausibly show that [the employer] imposed across-the-board training with the intention of forcing Norgren to quit.”

Religious discrimination claim fails for the same reason

To support his religious discrimination claim, Norgren alleged he was constructively discharged due to a hostile work environment resulting from the company’s “mandated training and refusal for exemption.”

As to the mandated training, the court reiterated its view that mandating diversity training did not plausibly show the company tried to force Norgren to quit.

And the refusal for the exemption could not support the constructive discharge claim because Norgren had already submitted his notice of retirement three weeks prior to the exemption denial, the court pointed out.

Court: Worker did not engage in protected activity

Turning to the retaliation claim, the court said it failed from the get-go because Norgren did not engage in a protected activity.

A protected activity means complaining about illegal workplace behavior.

Here, Norgren complained about mandated training, but “being required to attend across-the-board diversity training is not a discriminatory practice under Title VII,” the court explained. Case dismissed.

Norgren v. Minnesota Department of Human Services, No. 22-489 ADM/TNL, 2023 WL 35903 (D. Minn. 1/4/23).

Filed under
  • Employment Law
  • Share on

Get the HRMorning Newsletter

With HRMorning arriving in your inbox, you will never miss critical stories on labor laws, benefits, retention and onboarding strategies.

  • This field is for validation purposes and should be left unchanged.
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form

Free Training & Resources

White Papers

9 Strategies to Boost Employee Retention

Provided by Deputy

Webinars

Transform Your HR Department Into A Hiring Powerhouse

Webinars

AON LP: Grow Your Future Workforce from Within

White Papers

The True Cost of a Delayed Diagnosis

SPONSORED CONTENT

HR Technology

sponsored content
The Best AI Software for HR Automation

Courtesy of G-P

Talent Management

sponsored content
Powerful Employee Retention Strategies for 2025: How to Keep Your Best People

Courtesy of PEOPLEGURU

Benefits

Health Care

Wellness

sponsored content
Proven Results: 5 Ways Teladoc Health Chronic Condition Management Transforms HR Outcomes

Courtesy of TELADOC HEALTH

Further Reading

  • Employment Law
Lyft to Pay $2.1M FTC Fine: Actionable Takeaways For HR

Lyft Inc. recently agreed to settle a lawsuit filed by the federal government. Among other things, the company will pay a $2.1 million fine...

  • Employment Law
Equal pay dispute: Out-of-state remote employee wins first round in court

Scoring a significant preliminary victory, an out-of-state remote employee who lives and works in New Hampshire will be allowed to pursue p...

  • Employment Law
  • HR Technology
Common Compliance Mistakes – And How HR Tech Can Help Fix Them

Staying on top of compliance is no small feat these days. For HR pros, especially those at small- to medium-sized businesses (SMBs) with li...

  • Employment Law
Fired Over Pregnancy? Plant Nursery to Pay $40K to Settle EEOC Lawsuit

When employers mishandle pregnancy leave, the risks go beyond inconvenience – they can lead to legal trouble and financial penalties. A M...

  • Employment Law
FMLA rules put HR pros to the test: 5 pitfalls to avoid

When it comes to laws that require HR pros to put on their thinking caps and really think things through, the federal Family and Medical Le...

  • Employment Law
She claims race bias, but others say she’s the problem: Now what?

HR pros are put in a tough spot when an investigation shows that an employee who alleges race bias or other mistreatment might actually be ...

Get the latest from HRMorning in your inbox PLUS immediately access 10 FREE HR guides.

I WANT MY FREE GUIDES
HR Morning Logo
  • Facebook
  • Linked In
  • ABOUT HRMORNING
  • ADVERTISE WITH US
  • WRITE FOR US
  • CONTACT
  • Employment Law
  • Benefits
  • Recruiting
  • Talent Management
  • Performance Management
  • HR Technology
  • Leadership & Strategy
  • Compensation
  • Policy & Procedures
  • Wellness
  • Staff Departure
  • HR Career & Self-Care
  • Health Care
  • Retirement Plans
  • DEI

HRMorning, part of the Rover Insights Network, provides the latest HR and employment law news for HR professionals in the trenches of small-to-medium-sized businesses. Rather than simply regurgitating the day's headlines, HRMorning delivers actionable insights, helping HR execs understand what HR trends mean to their business.

Powered By Rover Insights
Privacy Policy | Terms of Service
Copyright© 2026 Rover Insights
HRMorning Logo

WELCOME BACK!

Enter your username and password below to log in

Forget Your Username or Password?

Reset Password

Lost your password? Please enter your username or email address. You will receive a link to create a new password via email.

Log In

Why do we need your credit card for a free trial?

We ask for your credit card to allow your subscription to continue should you decide to keep your membership beyond the free trial period.  This prevents any interruption of content access.

Your card will not be charged at any point during your 21 day free trial
and you may cancel at any time during your free trial.

During your free trial, you can cancel at any time with a single click on your “Account” page.  It’s that easy.