In Groff v. DeJoy, the U.S. Supreme Court recently decided an employee religious-accommodations case that fundamentally shifts the legal standard under Title VII.
An employee with a sincerely held religious belief that Sundays should be devoted to worship and rest had a position with the United States Postal Service that generally did not require him to work on Sundays. However, as USPS began facilitating more deliveries for Amazon on Sundays, the employee transferred to a more rural post office to avoid the requirement to work on Sundays. When the rural post office also began facilitating Amazon deliveries on Sunday, the employee refused to work on Sundays, and USPS redistributed his deliveries to other employees. The employee received progressive discipline based on his refusal to work Sundays, and he ultimately resigned.
The employee sued under Title VII of the Civil Rights Act, asserting that USPS could have accommodated his Sunday Sabbath practice without undue hardship to the USPS’s business. Both the district court and Third Circuit Court of Appeals held in USPS’s favor, finding that accommodating the employee’s religious belief would impose an “undue hardship” on USPS by create a “more than de minimis cost”—the standard that had been in place for years. The Supreme Court disagreed, however, deciding that, within the context of Title VII, in order for an accommodation to be considered an “undue hardship” for an employer, the burden must result in a substantial increase in costs related to the employer’s business.
This has shifted the standard in favor employees and is already causing courts to rethink some of their prior rulings.
Source: Groff v. DeJoy, 600 U.S. 447 (2023)
