US Supreme Court narrows employer’s ability to deny religious accommodations to employees News
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US Supreme Court narrows employer’s ability to deny religious accommodations to employees

The Supreme Court of the United States ruled Thursday in Groff v. DeJoy that challenges under Title VII of the Civil Rights Act for religious accommodation in the workplace would require employers to show substantially increased costs. The Court used this case to clarify a precedential case often relied on in Title VII cases, and made it easier for employees to seek religious accommodations in the workplace.

The problem that faced the Supreme Court was the lower court’s reliance on the case Trans World Airlines, Inc. v. Hardison, which set the standard of de minimus cost for the employer. The case stated that an employer only needed to accommodate religious practices if doing so did not impose a substantial cost that amounted to an undue hardship.

The Court upheld the Hardison precedent, keeping the de minimus standard, but added clarity as to its interpretation. The Court emphasized that the Hardison test should be used to consider all relevant factors that go into undue hardship and that Title VII still requires that an employer “reasonably accommodate” the chosen religious practices of their employees. Therefore, the employer has the burden of showing that accommodating employee religious requests would require a substantially increased cost to the business to receive an undue hardship exception.

Ranking member of the House of Representatives Committee on Education and the Workforce Robert C. Scott (D-VA), celebrated the ruling, saying:

Religious freedom is a fundamental American value.  Our civil rights laws protect workers from religious discrimination and proactively require employers to provide accommodations for religious exercise. Today’s Supreme Court ruling in Groff v. DeJoy clarified employers’ obligation to provide these reasonable accommodations when an employee’s sincerely held religious observances and practices conflict with work requirements.

The case was brought by Gerald Groff, who was an employee of the United States Postal Service (USPS) from 2012 until 2019. Groff identifies as an Evangelical Christian who, as a matter of religious observation, is unable to work on Sundays. When Groff first began working at USPS, this was not an issue, but in 2013, USPS began facilitating deliveries for Amazon and asked their employees to work on Sundays as well. Groff initially avoided this requirement by moving to a more rural location, but eventually, Amazon deliveries reached the rural office as well.

Groff received “progressive discipline” for his failure to work Sundays, and eventually resigned in 2019. He then brought legal action against USPS, alleging workplace religious discrimination, protected under Title VII. The District Court granted summary judgement to USPS, and the Third Circuit Court of Appeals affirmed.

The case will now be remanded to the lower courts for further proceedings using the clarified interpretation under Hardison.

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