Groff v. DeJoy

Gerald Groff, an evangelical Christian postal carrier, refused to work on Sundays due to his Sabbath observance after the U.S. Postal Service contracted with Amazon to deliver packages on that day. He was disciplined and eventually resigned, then sued for religious discrimination under Title VII of the Civil Rights Act. Lower courts ruled against him based on the 1977 precedent in Trans World Airlines v. Hardison, which stated that an employer suffers an “undue hardship” if an accommodation requires more than a minimal cost. The Supreme Court unanimously clarified that “undue hardship” means a substantial burden, not a minimal one, and that an employer must show the accommodation would result in substantial increased costs in relation to the conduct of its particular business. The case was remanded for further proceedings under this heightened standard.

The Supreme Court unanimously vacated the Third Circuit’s ruling and clarified the undue hardship standard. The Court held that an employer must show that the burden of granting a religious accommodation would result in substantial increased costs in relation to the particular business, rejecting the de minimis cost interpretation that had been widely applied since Hardison. The case was remanded for the lower courts to apply this clarified, more employee-protective standard.

The central dispute was whether the “undue hardship” standard under Title VII allows an employer to deny a religious accommodation merely because it imposes more than a de minimis, or minimal, cost, or whether the employer must prove that the accommodation would cause a substantial and unreasonable burden.

The ruling significantly strengthened protections for religious employees in the workplace. It overturned a widely criticized low bar that allowed employers to easily refuse accommodations, requiring them instead to demonstrate a substantial concrete burden. This decision was hailed by religious liberty advocates as a vital restoration of faith-based rights and is expected to force companies to more seriously consider scheduling and practice accommodations, leading to revised workplace policies across the nation.