Abstract: Machine learning systems based on minimizing average error have been shown to perform inconsistently across notable subsets of the data, which is not exposed by a low average error for the entire dataset. In consequential social and economic applications, where data represent people, this can lead to discrimination of underrepresented gender and ethnic groups. Distributionally Robust Optimization (DRO) seemingly addresses this problem by minimizing the worst expected risk across subpopulations. We establish theoretical results that clarify the relation between DRO and the optimization of the same loss averaged on an adequately weighted training dataset. A practical implication of our results is that neither DRO nor curating the training set should be construed as a complete solution for bias mitigation.