In a landmark ruling that will have far-reaching effects on workplaces across the country, the U.S. Supreme Court issued a unanimous decision reinforcing protections for employees pursuing religious accommodations under federal law.
The ruling, which sets out how employers should assess such requests, is one of the most significant interpretations of religious liberty at work in decades.
The case, Groff v. DeJoy, opened the question of whether an employer can require employees to perform work that violates their religious beliefs, and what level of accommodation for those beliefs is mandated in the workplace under Title VII of the Civil Rights Act of 1964. The Court’s June 29, 2023, 9–0 decision in favor of a Pennsylvania postal worker marked a somewhat unusual alignment of justices from opposing ends of the ideological spectrum.
The controversy involved the experience of Gerald E. Groff, a former U.S. Postal Service rural letter carrier in Lancaster County, Pennsylvania. Groff is a practicing Evangelical Christian and observes Sunday as a Sabbath day of rest and worship. For many years his position enabled him not to work on Sundays with little trouble, and his employer had been accommodating his religious beliefs. That changed once the Postal Service signed on with Amazon in 2013, obligating it to deliver packages on Sundays as part of a larger push to stay financially viable.
Groff was constantly assigned to Sunday shifts which would break his Sabbath as Sunday work became the norm. He pleaded to make up for the lost time by working more weekdays or holiday shifts, but he wasn’t allowed. In 2019, Groff resigned and sued, claiming that the Postal Service did not reasonably accommodate his religious beliefs.
At the center of the case was the meaning of “undue hardship” under Title VII of the Civil Rights Act. For decades, courts relied on a 1977 Supreme Court ruling that allowed employers to deny religious accommodations if they imposed more than a minimal cost. Critics argued this standard weakened protections for religious workers and made it too easy for employers to reject accommodation requests.
Groff’s lawyers that particular reading of the statute to be re-evaluated, contending that “undue hardship” should turn on a showing of substantial cost or significant operational disruption. Their argument was supported by numerous religious and civil rights groups, which expressed concern that the current standard places a burden on workers whose religious practices are different than the commonly accepted workplace norms.
Rejecting the long-held “more than de minimis” standard, the Supreme Court clarified that employers must point to more than “ordinary” increased costs when seeking to deny religious accommodations. Temporary chaos in a work schedule or coworker dissatisfaction are not undue hardships, the Court ruled.
The decision bolsters religious protections in the workplace and sets a precedent for employers to apply a more individualized approach to accommodation requests. While not guaranteeing Groff a particular result, it does give his claims for consideration under an interpretation of legal standards that more fully captures the purpose of federal civil rights law and further advances the understanding that workers should not be made to choose between their faith and their ability to make a living.
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