Employer Must Prove “Substantial Increased Costs” Would Result from Religious Accommodation

Groff v. DeJoy, 600 U.S. ___, 143 S. Ct. 2279 (2023)

Gerald Groff, an Evangelical Christian, took a mail delivery job with the USPS at a time when postal service employees were was not required to work on Sundays.  However, when the USPS began facilitating Sunday deliveries for Amazon, he was called upon to work Sundays, which ultimately resulted in his resignation from his employment after he was subjected to progressive discipline for refusing to work Sundays.  Groff sued the USPS for violation of Title VII, alleging the postal service could have accommodated his Sunday Sabbath practice “without undue hardship on the conduct of [its] business.” 

The district court and the Court of Appeals for the Third Circuit ruled in favor of the USPS, holding that requiring an employer “to bear more than a de minimis cost to provide a religious accommodation is an undue hardship.”  The lower courts held that exempting Groff from Sunday work had “imposed on his coworkers, disrupted the workplace and workflow, and diminished employee morale.”  In this unanimous decision, the Supreme Court clarified earlier precedent (Trans World Airlines, Inc. v. Hardison, 432 U.S. 63 (1977)) and vacated the lower court’s opinion, holding that an employer can show “undue hardship” when the burden of granting a religious accommodation would result in substantial increased costs in relation to the conduct of its particular business.