The school system in my county, Arlington, Virginia, certainly knows how to waste taxpayers' money. Like several school districts, they've hired an infamous race-baiting “diversity consultant,” Glenn Singleton, whose racist theories drew criticism from four Supreme Court justices this year in the landmark court case of Parents Involved in Community Schools v. Seattle School District No. 1. As I noted earlier, Glenn Singleton of Pacific Educational Group has gotten rich promoting racism, racial division, and scapegoating in the schools. School systems hire him for hundreds of thousands of dollars to stereotype and scapegoat people based on their race under the guise of “diversity training.” In 2002, the Seattle Schools hired him to “educate” their students and staff about racism. Singleton promotes the crudest imaginable racial stereotypes, such as claiming that “'white talk' is â€˜verbal, impersonal, intellectual' and â€˜task-oriented,' while â€˜color commentary' is â€˜nonverbal, personal, emotional' and â€˜process-oriented.'” He incessantly complains about “the ubiquity of white privilege and racism.” To illustrate how white people should behave, he points to an ashamed, self-hating white teacher who said that "although I often try to seek counsel of colleagues of color, it is inevitable that times arise where it's only after the fact that one of them points out some flaw in my reasoning. The flaws are often the result of my ingrained Whiteness and my own blindness to its perpetual presence." Under Singleton's influence, the Seattle Schools defined “individualism” as a form of “cultural racism,” said that only whites can be racist, and claimed that planning ahead ("future time orientation”) is a white characteristic that it is racist to expect minorities to exhibit. In June 2007, the Supreme Court struck down the Seattle Schools' use of race in student assignment, and 4 of the 9 justices cited Seattle's wacky, Singleton-influenced, definitions of racism in the course of their opinions. Justice Thomas, for example, cited those definitions in footnote 30 of his opinion to explain why the courts should not defer to school districts when they use race. Likewise, Chief Justice Roberts cited those definitions in footnote 14 of his opinion for the Court. (In most cases, as in the Seattle case itself, the courts had upheld the use of race in student assignment based on the concept of “deference” to school officials. In a number of other cases, though, the lower courts struck down the use of race in student assignment as being too extreme. One such case involved the Arlington County schools, which were barred from using race by the federal courts in Tuttle v. Arlington County Public Schools (1999)). Despite greatly embarrassing the Seattle School District, which hired him, Singleton continues to be hired by school superintendents to preach his weird message of racism and scapegoating. For example, a Colorado school district gave Singleton a “six-figure consulting contract.” Singleton has received hundreds of thousands of dollars to barrage captive audiences with racism and hate. Yet he thinks he's oppressed and the victim of "racial marginalization." If Singleton inflicts his racist insults on a captive audience of teachers at a training seminar, they may well have a Section 1981 or Section 1983 claim against him for racial harassment. As cases such as Markham v. White (1999) and Ascolese v. SEPTA (1996) show, the amount of repeated abuse required for a hostile training environment claim by a public employee is much lower than for a hostile work environment claim, where isolated racist remarks are not actionable. Moreover, he may be subject to individual liability for aiding and abetting discrimination under 42 U.S.C. 1981. Contrary to Singleton's racist belief, racism is not a white monopoly, as the federal appeals courts have recognized in holding institutions liable for harassing or mistreating their white employees. See, e.g., Bowen v. Missouri Department of Social Services (2002) (racial harassment of white employee by black co-worker); Taxman v. Board of Education (1996) (school board liable for termination of white teacher). Arlington County and Singleton should keep in mind that “diversity” training seminars that denigrate people based on their race or gender can give rise to successful harassment lawsuits, such as Hartman v. Pena (1995), which allowed a white male to sue for sexual harassment over an insulting gender-awareness seminar, and Robinson v. Reed (1978), which allowed a woman to sue for invasive questions in a race-relations seminar. Singleton's bizarre racial theories have been criticized by many commentators, such as Rocky Mountain News editor Vincent Carroll; legal commentator John Rosenberg; education writer Joanne Jacobs; and legal commentator Walter Olson (creator of the world's first law blog, the widely-read Overlawyered), among many others. Yet he continues to profit from the ignorance of the school officials, who hire him and give him a platform in which to promote racial division and racism in the schools.