The Supreme Court sided with an evangelical Christian postal worker in a Thursday decision, stating that companies need to prove a substantial hardship when denying an employee’s requested accommodations.
Justice Alito delivered the opinion for a unanimous Court. Sonia Sotomayor filed a concurring opinion, and Ketanji Jackson joined.
Gerald Groff brought forth a case against the US Postal Service, claiming that they could have accommodated his request to have Sundays off in accordance with his Christian belief that Sundays are a day of worship and rest.
In the ruling, the court unanimously overturned the 1977 Trans World Airlines v Hardison ruling that said employees had to "reasonably accommodate" an employee’s religious beliefs and practices, so long as they didn’t create an "undue hardship" on the business, according to Fox News.
The 1977 ruling, which built on Title VII of the Civil Rights Act that required religious accommodations for employees, said that these accommodations could be denied if they impose a "de minimis," or minimal, cost on the business.
Groff’s attorney argued that "de minimis" should be scrapped in favor of the original language of Title VII, which would define "undue burden" in line with other federal laws.
"To be sure, as the Solicitor General notes, some lower courts have understood that the protection for religious adherents is greater than ‘more than … de minimus' might suggest when read in isolation," Justice Samuel Alito wrote. "But a bevy of diverse religious organizations has told this Court that the de minimus test has blessed the denial of even minor accommodation in many cases, making it harder for members of minority faiths to enter the job market."
"We hold that showing ‘more than a de minimus cost,’ as that phrase is used in common parlance, does not suffice to establish ‘undue hardship’ under Title VII. Hardison cannot be reduced to that one phrase."
Groff had worked as a fill-in mail carrier with the Post Office in Pennsylvania, filling in when other mail carriers were off.
In 2013, the USPS was contracted by Amazon to deliver packages, which required Sunday shifts from the workers.
Initially, Groff was able to transfer to another branch that did not deliver on Sundays, but when that branch also began Sunday deliveries, Groff was permitted to miss Sunday shifts if he was able to find someone to cover his shift. Groff was frequently unable to find someone to fill in, and missed over two dozen Sunday shifts.
Officials said Groff’s absences had created a tense environment at work and created morale problems. It also meant that other workers had additional mail to deliver on Sundays. Groff resigned from his job in 2019, believing that he would be fired for missing Sunday shifts.
Groff obtained representation and filed a federal lawsuit against the Postal Service, claiming that the USPS could have accommodated his requests. The Third Circuit Court of Appeals ruled in May 2022 that the USPS would have endured undue hardship in Groff was allowed Sundays off.
The Supreme Court vacated the lower court’s judgment and has remanded the case for further proceeding consistent with Thursday’s decision.
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