U.S. Supreme Court building in Washington, D.C. (Photo: Diego M. Radzinschi/ALM)
On June 29, 2023, the U.S. Supreme Court in Groff v. DeJoy clarified the “undue hardship” standard under which an employer may deny a religious accommodation under Title VII of the Civil Rights Act of 1964. In a unanimous opinion authored by Justice Samuel Alito, the court rejected a “de minimis cost” test and held that an employer denying a religious accommodation must show that the burden of granting an accommodation “would result in substantial increased costs in relation to the conduct of its particular business.”
The case was brought by Gerald Groff, a U.S. Postal Service mail carrier who believed for religious reasons that Sundays should be devoted to worship and rest. When Groff refused to work Sundays, USPS redistributed his Sunday deliveries to other staff and disciplined Groff, who later resigned. Groff then sued USPS under Title VII, asserting that USPS could have accommodated his Sunday Sabbath practice without undue hardship.
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