Groff v. DeJoy
Headline: Court rejects the 'de minimis' test and clarifies Title VII requires employers to show substantial increased costs to deny religious accommodations, affecting workplace Sabbath requests and employer scheduling practices nationwide.
Holding: The Court held that under Title VII an employer must show that granting a religious accommodation would cause substantial increased costs in relation to its particular business, not merely more than de minimis costs.
- Rejects 'de minimis' defense and raises burden on employers to justify denying religious accommodations.
- Coworker dislike cannot justify denying accommodation unless it harms business operations.
- Remands for lower courts to apply the 'substantial increased costs' test.
Summary
Background
Gerald Groff is an Evangelical Christian who objects to working on Sundays. He worked as a rural mail carrier for the United States Postal Service. After USPS began Sunday deliveries for Amazon, Groff sought to avoid Sunday work, transferred to a small station, and ultimately had his Sunday deliveries reassigned, received progressive discipline, and resigned. He sued under Title VII, arguing USPS could have accommodated his Sabbath observance without undue hardship. The District Court granted summary judgment to USPS and the Third Circuit affirmed under a reading of Trans World Airlines v. Hardison that used a 'more than de minimis' test.
Reasoning
The Court addressed what “undue hardship” means under Title VII. It held that the line in Hardison about costs being “more than a de minimis” cannot stand alone. Instead, an employer must show that granting an accommodation would cause substantial increased costs in relation to the conduct of its particular business. Courts must consider all relevant facts, including the nature, size, and operating costs of the employer, and examine practical impacts of proposed accommodations. Effects on co-workers matter only if those effects translate into harms to the employer's business. Employers must explore reasonable alternatives, not simply reject a request after considering one option.
Real world impact
The decision makes it harder for employers to deny modest religious accommodations by relying on a trivial-cost rule. Workers seeking religious time off or schedule changes may receive more meaningful consideration. The Court vacated the Third Circuit's decision and remanded for lower courts to apply the clarified “substantial increased costs” standard and to decide any remaining factual issues.
Dissents or concurrances
Justice Sotomayor, joined by Justice Jackson, concurred. She emphasized stare decisis, noted that the conduct of a business includes effects on employees, and agreed employers cannot rely on trivial-cost defenses to deny accommodation.
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