Groff v. DeJoy
600 U.S. 447
SCOTUS2023Background:
- Gerald Groff, an Evangelical Rural Carrier Associate for USPS, refused to work on Sundays for Sabbath reasons after USPS began Sunday deliveries for Amazon.
- Groff transferred to a rural station to avoid Sunday work, but Sunday deliveries later began there; USPS reassigned his Sunday routes to coworkers and issued progressive discipline until he resigned.
- Groff sued under Title VII §2000e(j), claiming USPS failed to reasonably accommodate his religious observance without undue hardship.
- The District Court granted summary judgment for USPS; the Third Circuit affirmed, applying Trans World Airlines v. Hardison and its “more than de minimis” reading of undue hardship.
- The Supreme Court granted certiorari to clarify Hardison’s scope and whether the de minimis test governs Title VII accommodations.
- The Court vacated and remanded, holding that “undue hardship” requires substantial increased costs in relation to the employer’s business (not merely more-than-de-minimis costs), and left fact-specific application to lower courts.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper legal standard for “undue hardship” under Title VII | De minimis is incorrect; employer must show significant difficulty or expense | Hardison governs; but the government agreed de minimis should not be read literally and emphasized substantial-cost language | "Undue hardship" requires substantial increased costs relative to the conduct of the particular business; de minimis is insufficient |
| Whether Hardison’s “more than a de minimis cost” is controlling | Hardison should be overruled or clarified away from de minimis | Hardison need not be overruled; its context matters and refers to substantial burdens | Hardison cannot be reduced to its de minimis phrase; courts must assess hardship in context and focus on substantial burdens |
| Relevance of coworker impacts or employee animus to undue hardship | Burdens on coworkers show operational hardship on employer | Only coworker effects that demonstrably affect the conduct of the business are relevant; animus is not cognizable | Coworker impacts matter only if they logically affect the conduct of the business; hostility or animus toward religion cannot justify undue hardship defense |
| Required scope of employer’s accommodation effort | Employer must reasonably accommodate and consider alternatives beyond a single option | Employer can rely on infeasibility of particular options | Employer must consider reasonable alternative accommodations (e.g., voluntary swaps); cannot stop analysis after rejecting one option |
Key Cases Cited
- Trans World Airlines, Inc. v. Hardison, 432 U.S. 63 (U.S. 1977) (central precedent on Title VII religious accommodation and seniority; court clarifies the de minimis language is not dispositive)
- EEOC v. Abercrombie & Fitch Stores, Inc., 575 U.S. 768 (U.S. 2015) (Title VII gives religious practices favored treatment; employer intent standard)
- Teamsters v. United States, 431 U.S. 324 (U.S. 1977) (recognition of bona fide seniority systems under Title VII)
- Lemon v. Kurtzman, 403 U.S. 602 (U.S. 1971) (Establishment Clause test discussed as background for statutory concerns)
- Dewey v. Reynolds Metals Co., 429 F.2d 324 (6th Cir. 1970) (pre-1972 holding that employers were not required to accommodate Sabbath observance; prompted congressional amendment)