22-174 Groff V. DeJoy (06/29/2023).pdf

## Groff v. DeJoy (2023) - Concise Summary

Issue: Does Title VII of the Civil Rights Act of 1964 require employers to accommodate religious observances without causing "undue hardship" on their business?

Background: Petitioner Gerald Groff, a Christian who observes Sunday as a Sabbath, worked for the U.S. Postal Service (USPS). USPS agreed to facilitate Sunday deliveries for Amazon, requiring Groff to work Sundays or transfer to a different station. He refused and was disciplined for insubordination. Groff sued, claiming USPS discriminated against him based on his religion by not accommodating his Sabbath practice.

Lower Courts: The District Court and Third Circuit Court of Appeals ruled in favor of USPS, stating that exempting Groff from Sunday work would cause "undue hardship" to the employer. They relied on this Court's precedent in Trans World Airlines, Inc. v. Hardison (1972), which held that employers need not accommodate religious practices if doing so creates more than a "de minimis cost."

Supreme Court Decision:

The Court reversed and remanded, holding:

- Statutory Interpretation: Title VII requires employers to reasonably accommodate religious observances unless doing so would cause "undue hardship" on the business. The term "undue hardship" means substantial increased costs in relation to the conduct of the employer's particular business.

- Hardison Context: While Hardison discussed a "de minimis cost" standard, the Court's opinion focused on preventing "substantial" or "significant" expenditures and disruptions. The Court emphasized that Hardison did not establish a rigid "de minimis" rule but rather considered the specific circumstances of each case.

- Application: This case differs from Hardison because USPS had alternative options to accommodate Groff (e.g., redistributing his Sunday deliveries) without causing substantial increased costs or disruptions.

Impact: The decision clarifies that employers must carefully assess the impact of accommodating religious requests and only deny them when necessary to avoid significant business burdens.