Groff v. DeJoy

Background

Gerald Groff is an Evangelical Christian who worked for the United States Postal Service and objected to working on Sundays for religious reasons after USPS began Sunday deliveries for Amazon. Groff moved to a rural station to avoid Sunday shifts, continued to refuse Sunday work when deliveries expanded, received discipline, and eventually resigned. He sued under Title VII arguing USPS could have accommodated his Sabbath practice without undue hardship. The District Court and the Third Circuit granted summary judgment to USPS, applying a rule that an employer need not accommodate if the cost is “more than de minimis.”

Reasoning

The Court reviewed the history of Title VII and the old Trans World Airlines v. Hardison decision. It held that “more than a de minimis cost” is too weak a test. Instead, an employer defending a denial must show that granting the accommodation would cause substantial increased costs in relation to the conduct of its particular business. The Court explained that impacts on coworkers matter only if they logically affect how the business is run, that hostility or bias toward a religion cannot be treated as a business hardship, and that employers must consider alternative accommodations, not just reject the request out of hand.

Real world impact

The Court vacated the Third Circuit’s judgment and remanded for further proceedings under the clarified standard. Lower courts must now re-evaluate religious-accommodation claims using the substantial-cost test and may need additional factual development. The Court left many EEOC guidelines intact but declined to adopt any detailed new rules itself.

Dissents or concurrances

Justice Sotomayor, joined by Justice Jackson, concurred, stressing stare decisis and agreeing that Hardison’s de minimis line should not control the statutory meaning but that Hardison’s facts and seniority concerns remain relevant.