This Littler Lightbulb highlights some of the more significant employment and labor law developments at the U.S. Supreme Court and federal courts of appeal over the last month.

At the Supreme Court

• Oral Argument on Title VII Religious Accommodation Standard. On April 18, 2023, the U.S. Supreme Court heard oral argument in Groff v. DeJoy, assessing the standard for determining whether accommodating a religious employee’s request for time off creates an “undue hardship.” A decision in the case is expected before the end of the Court’s current term in June.

In the Federal Appellate Courts

• FLSA Administrative Exemption. In Walsh v. Unitil Serv. Corp., 64 F.4th 1 (1st Cir. Mar. 22, 2023), the First Circuit vacated summary judgment granted to a public utility company, finding the district court did not apply the appropriate analysis in determining that the company’s electric distribution dispatchers and gas controllers were exempt administrative employees under the federal Fair Labor Standards Act. The issue in the case was whether the employees’ “primary duty is the performance of office or non-manual work directly related to the management or general business operations of the employer or the employer’s customers” in accordance with the DOL regulations applicable to the administrative exemption. In making its determination, the First Circuit applied what it termed a “relational” analysis explaining that if the employees’ primary duties relate to the business purpose of...

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