On Thursday, June 29, 2023, the U.S. Supreme Court ruled in favor of Gerald Groff, a former United States Postal Service worker who resigned due to not receiving religious accommodations over Sunday hours.
The Supreme Court held that Title VII of the Civil Rights Act requires employers that deny religious accommodations for employees must show that the burden of granting accommodations would result in substantially increased costs in relation to the conduct of its particular business. The Court examined the background of Trans World Airlines, Inc. v. Hardison to explain the disposition of Groff v. DeJoy. “Even though Hardison‘s reference to ‘de minimis‘ was undercut by conflicting language and was fleeting in comparison to its discussion of the ‘principal issue’ of seniority rights, lower courts have latched on to ‘de minimis‘ as the governing standard.” However, the Supreme Court held that “showing ‘more than a de minimis cost,’ as that phrase is used in common parlance, does not suffice to establish ‘undue hardship’ under Title VII.” Rather, the Court explained that “‘undue hardship’ is [a fact-specific inquiry and is] shown when a burden is substantial in the overall context of an employer’s business.”
The Court then declined to adopt either of the elaborations of the applicable standard proposed by each party. “What is most important is that ‘undue hardship’ in Title VII means what it says, and courts should resolve whether a hardship would be substantial in the context of an employer’s business in the commonsense manner that it would use in applying any such test.” The Court then clarified that “[i]mpacts on coworkers are relevant only to the extent those impacts go on to affect the conduct of the business. A court must analyze whether that further logical step is shown.” Further, “Title VII requires that an employer ‘reasonably accommodate’ an employee’s practice of religion, not merely that it assess the reasonableness of a particular possible accommodation or accommodations.”
The Court then remanded the case for consideration under the clarified standard. Justice Alito wrote the opinion for the unanimous court. Justice Sotomayor filed a concurring opinion, in which Justice Jackson joined.
Additional Reading
Postal worker who quit over Sunday hours gets new chance for religious-bias claim, thanks to Supreme Court, ABA Journal (June 29, 2023)
Groff v. DeJoy, 600 U.S. ___ (2023)
Supreme Court to Review Religious Discrimination Standard in Title VII Case, Justia Legal News (January 18, 2023)
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