Groff v. DeJoy
600 U.S. 447
SCOTUS2023Background
- Gerald Groff, an Evangelical Christian, refused to work on Sundays for religious reasons after USPS began facilitating Sunday Amazon deliveries.
- Groff worked as a Rural Carrier Associate; he transferred to avoid Sunday routes, but Sunday deliveries later began at his new station.
- USPS redistributed Groff's Sunday assignments to other employees, issued progressive discipline, and Groff eventually resigned and sued under Title VII § 2000e(j) for failure to reasonably accommodate his Sabbath observance.
- The district court granted summary judgment for USPS; the Third Circuit affirmed, applying Trans World Airlines v. Hardison’s “more than de minimis cost” formulation to find undue hardship.
- The Supreme Court granted certiorari to clarify Hardison, held that “more than de minimis” is not the proper test, and vacated and remanded for application of a clarified, context-specific standard.
Issues
| Issue | Plaintiff's Argument (Groff) | Defendant's Argument (USPS / Gov.) | Held |
|---|---|---|---|
| Proper test for “undue hardship” under Title VII | Title VII requires a "significant difficulty or expense" standard (more than trivial) | Hardison’s language should be read in context; not literally de minimis; emphasize substantial burdens | Court: “more than de minimis” is insufficient; undue hardship requires showing substantial increased costs in relation to the conduct of the employer’s particular business |
| Whether Hardison must be overruled | Hardison’s de minimis phrase should be abandoned in favor of a clearer, stricter standard | Hardison remains binding but should not be read literally to permit trivial denials | Court: Hardison is not reduced to its de minimis line; interpreted consistently with its references to substantial costs, but not overruled |
| Relevance of coworker impacts and bias to undue hardship | Coworker inconvenience alone does not establish undue hardship on the employer’s business | Impacts on coworkers (e.g., disrupted workflow, morale) demonstrate burden on business | Court: Coworker impacts are relevant only insofar as they demonstrably affect the conduct of the employer’s business; hostility or animus toward religion cannot justify denial |
| Employer’s obligation to consider alternatives | Employer must explore reasonable accommodations (voluntary swaps, incentives, schedule changes) not just assert one option is undue | Employer may rely on evidence that particular accommodations (e.g., forcing overtime) would be undue | Court: Employer must reasonably accommodate and consider alternative options; cannot stop analysis after rejecting a single accommodation without assessing others |
Key Cases Cited
- Trans World Airlines, Inc. v. Hardison, 432 U.S. 63 (1977) (original source of “more than a de minimis cost” language; Court’s discussion centered on seniority and substantial burdens)
- EEOC v. Abercrombie & Fitch Stores, Inc., 575 U.S. 768 (2015) (Title VII requires accommodation of religious practice to enable participation in workforce)
- Teamsters v. United States, 431 U.S. 324 (1977) (recognition of special treatment for bona fide seniority systems under Title VII)
- Lemon v. Kurtzman, 403 U.S. 602 (1971) (contextual background on Establishment Clause concerns referenced in Hardison)