Washington — The Supreme Court on Thursday sided with a Christian mail carrier who declined to work on Sundays, bolstering protections for workers seeking religious accommodations from their employers.
In a unanimous decision in the case known as Groff v. DeJoy, the court declined to overturn a key 1977 precedent that said employers can deny accommodations for an employee’s religious practices if the request imposes more than a “de minimis,” or minimal, cost on the business.
But it set aside the “de minimis” standard set more than 45 years ago and laid out a “clarified standard” for lower courts to apply to determine when, under Title VII of the Civil Rights Act, an employee’s proposed religious accommodation imposes an undue hardship on the employer’s business.
As Justice Samuel Alito wrote for the majority, 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.”
“We think it is enough to say that an employer must show that the burden of granting an accommodation would result in substantial increased costs in relation to the conduct of its particular business,” he wrote.
The Supreme Court tossed out the lower court’s decision against the U.S. Postal Service worker, Gerald Groff, and sent the case back for further legal proceedings.
Title VII prohibits an employer from discriminating against a worker because of their religion. Under the law, an employer must reasonably accommodate an employee’s religious observance or practice unless it would result in “undue hardship” on the business.
In its 1977 decision in Trans World Airlines v. Hardison, the Supreme Court said an “undue hardship” is an accommodation that would cause an employee to bear more than a “de minimis” cost.
Thursday’s ruling is the latest in a string of decisions from the conservative Supreme Court in favor of religious parties. In its last term, the high court sided with a former high school football coach who was punished for praying on the field after games, and found that schools that provide religious instruction could not be excluded from a tuition assistance program offered by the state of Maine.
This latest dispute arose from Groff’s objections to working on Sundays after the Postal Service entered into an agreement with Amazon for Sunday package deliveries. Groff, an Evangelical Christian, said his religious beliefs prevented him from working those days because he observes the Sabbath on Sunday.
Groff was exempted from Sunday work while he was employed as a Rural Carrier Associate, or part-time mail carrier, at the post office in Quarryville, Pennsylvania. That changed when he transferred to a smaller station in Holtwood, Pennsylvania, that began Sunday deliveries in 2017.
The postmaster of the Holtwood Post Office refused to exempt Groff from Sunday delivery, but offered to seek volunteers to cover his shifts. Still, he ultimately missed 24 shifts when a replacement carrier couldn’t be secured to accommodate his absence.
After the Postal Service took disciplinary action against Groff due to his missed shifts, he resigned in 2019. Groff then sued the Postal Service in federal court, alleging it violated Title VII. A federal district court ruled in favor of the Postal Service, and a divided panel of judges on the U.S. Court of Appeals for the 3rd Circuit affirmed the ruling.
The appeals court found that exempting Groff from working on Sundays “caused more than a de minimis cost on USPS because it actually imposed on his coworkers, disrupted the workplace and workflow, and diminished employee morale.”
But the Supreme Court said that when faced with a request for an accommodation like Groff’s, “it would not be enough for an employer to conclude that forcing other employees to work overtime would constitute an undue hardship. Consideration of other options, such as voluntary shift swapping, would also be necessary.”
The court said the Postal Service could still prevail in its dispute with Groff, leaving the question to the lower courts to decide under the “clarified standard.”
