Summary: An employer must accommodate an employee’s religious beliefs unless it can show that doing so would “result in substantial increased costs in relation to the conduct of its particular business.”

Facts: Plaintiff, United States Postal Service (“USPS”) “Rural Carrier Associate” Gerald Groff, refused to work on Sundays, instead holding the day out for rest and worship in accord with his Evangelical Christian beliefs. After an agreement between USPS and Plaintiff’s union (the National Rural Letter Carrier’s Association) was made, USPS required its employees. including Groff, to make deliveries on Sundays and holidays. The agreement specified a particular order in which USPS employees would be called to work on Sundays. First would be part-time “Assistant Rural Carriers,” then volunteers, and last would be any available carrier who would be called on a rotating basis. This last category included Plaintiff. With Plaintiff unwilling to make Sunday deliveries, USPS made other arrangements, including requiring other employees (including the postmaster) to pick up Plaintiff’s deliveries. This arrangement continued for nearly two years, with Plaintiff receiving progressive discipline each time he missed a Sunday shift. Plaintiff eventually resigned in 2019 and brought suit against USPS under Title VII of the Civil Rights Act of 1964, arguing that USPS could have accommodated his Sunday practice “without undue hardship on the conduct of [its] business.” The district court...

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