Groff v. DeJoy

“‘More than a de minimis cost…’ does not suffice to establish ‘undue hardship’ under Title VII.” “Undue hardship” under Hardison “is shown when a burden is substantial in the overall context of an employer’s business.”

Petitioner, an Evangelical Christian who believes Sunday should be devoted to worship and rest, worked for United States Postal Services (“USPS”) as a Rural Carrier Associate. After USPS began facilitating Sunday deliveries, they had to make arrangements to accommodate Petitioner’s unwillingness to work on Sundays. He received “progressive discipline” until he resigned and filed a Title VII suit. The District Court granted summary judgment in favor of USPS and the Third Circuit Court of Appeals affirmed, finding that Petitioner’s exemption from Sunday work “imposed on his coworkers, disrupted the workplace and workflow, and diminished employee morale.” “‘More than a de minimis cost…’ does not suffice to establish ‘undue hardship’ under Title VII.” “Undue hardship” under Hardison “is shown when a burden is substantial in the overall context of an employer’s business.” The Court found no undue hardship resulting from temporary costs, swapping of shifts, or administrative costs in accordance with 29 CFR § 1605.2(d). The Court reasoned “undue hardship” must take all relevant factors, the accommodations at issue and their impact in “light of the nature, ‘size and operating cost of [an] employer.’” An undue hardship grounded in animosity towards a religion, religion in general or to the idea of accommodating religion is not “undue.” Vacated and remanded.