Title VII of the Civil Rights Act of 1964 prohibits discrimination in employment on the basis of religion. Employers are required to make a good-faith effort to grant employees’ requests for religious accommodations in the workplace, but they are not required to grant a request that would impose an “undue hardship” on their business.
In this case, part-time postal carrier Gerald Groff requested a religious accommodation from his employer, a small post-office in Pennsylvania, to not work Sunday shifts due to his religious beliefs. As a part-time employee, Groff’s job duties specifically required him to provide coverage for absent full-time employees on an as-needed basis, including on weekends and holidays. Yet over 14 months, Groff refused to show up for 24 Sunday shifts, leading other employees – nearly all of whom were also church-going Christians – to resign, transfer, file grievances, or cover for him. After receiving repeated discipline for these absences, Groff ultimately resigned and sued, claiming that the United States Postal Service had failed to reasonably accommodate his religious practice.
The federal district court ruled against Groff, holding that the Postal Service had met its responsibility to reasonably accommodate him by rearranging shifts to lessen the work-religion conflict and that further accommodations would have imposed an undue hardship on the business. The court of appeals agreed that exempting Groff from Sunday work entirely would have resulted in undue hardship to the Postal Service “because it actually imposed on his coworkers, disrupted the workplace and workflow, and diminished employee morale.” Groff, whose attorneys include two groups that endeavor to destroy church-state separation, then asked the Supreme Court to clarify the meaning of “undue hardship” and decide whether an employer may rely on harms to coworkers in denying an accommodation.
On March 30, 2023, Americans United and Lambda Legal filed an amicus brief concerning the second issue, arguing that Title VII permits employers to consider whether accommodations would impose financial, logistical, health and safety, dignitary, or other burdens on coworkers. And while workplace morale is an important consideration, employers cannot deny accommodations due to coworkers’ or customers’ religious hostility, as that would run counter to Title VII’s purpose of eradicating workplace discrimination.
On June 29, 2023, the Court issued a unanimous decision largely agreeing with our position. The Court held that “undue hardship” means a “substantial burden” in the overall context of an employer’s business, and importantly, that impacts on coworkers are relevant to that analysis. The Court also agreed that “bias or hostility to a religious practice” cannot justify denying an accommodation. The Court remanded this case to the lower court to apply this clarified standard to the facts of Groff’s case.