Groff v. DeJoy

Gerald Groff, an evangelical Christian and rural mail carrier for the United States Postal Service, refused to work on Sundays due to his religious belief in Sabbath observance. After USPS began delivering Amazon packages on Sundays, Groff was disciplined for failing to report to Sunday shifts. He sued under Title VII of the Civil Rights Act of 1964, alleging religious discrimination and failure to accommodate. Lower courts applied the longstanding "more than de minimis cost" standard from Trans World Airlines v. Hardison, ruling in favor of USPS. The Supreme Court granted certiorari to reconsider the undue hardship standard. On June 29, 2023, the Court unanimously clarified that an employer denying a religious accommodation must show that the accommodation would result in substantial increased costs in relation to the conduct of its particular business, rejecting the de minimis interpretation. The case was remanded for further proceedings consistent with this clarified standard.

The Supreme Court unanimously vacated the Third Circuit's decision and remanded the case, holding that "undue hardship" under Title VII requires an employer to show that granting a religious accommodation would result in substantial increased costs in relation to the conduct of its particular business, not merely a more than de minimis cost.

Whether Title VII's "undue hardship" defense permits an employer to deny a religious accommodation merely by showing that it would impose more than a de minimis cost, or whether the employer must demonstrate a substantial burden on its business.

The decision significantly strengthened workplace religious accommodation protections by raising the bar for employers to deny requests, prompting many employers to revise accommodation policies and likely increasing religious accommodation litigation, while affirming employees' rights to observe their faith without undue employer burden.