On June 29, 2023, the U.S. Supreme Court announced its unanimous opinion in Groff v. DeJoy, No. 22-174, 600 U.S. __ (2023), a long-awaited decision explaining employers’ obligations under Title VII to reasonably accommodate employees’ religious beliefs, observances and practices. Groff, the first Supreme Court decision in nearly 50 years to consider what employers must prove in order to deny an employee’s request for an accommodation based on religion, establishes that employers must show that the hardship associated with granting a religious accommodation would result in substantial increased costs in relation to the conduct of its particular business.
Gerald Groff is an Evangelical Christian who devotes his Sundays to worship and rest for religious reasons and believes that Sundays should not be devoted to “secular labor” and the “transport[ation]” of “worldly goods.” He was also a postal worker for the U.S. Postal Service (USPS) for many years. As we all know, until the mid-2010s, the USPS did not deliver mail on Sundays, so, for the first few years of his employment with the USPS, Mr. Groff’s religious observations did not conflict with his duties. But that changed in 2013 when the USPS agreed to assist Amazon by facilitating Sunday deliveries. In 2016, the USPS and Mr. Groff’s union entered into an understanding regarding how Sunday and holiday parcel delivery would be administered and how postal workers would be permitted to volunteer, or, if necessary, required, to...
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