31:
378:, Pennsylvania soon became an important hub and started delivering Amazon packages from 2015 onwards. Groff was initially an RCA at the Quarryville post office and informed the USPS of his religious need and his inability to work on Sundays. Accordingly, the USPS moved to accommodate his religious requirements by allowing him not to work on Sunday insofar as he covered the other shifts throughout the week.
450:, which he did. The burden then shifted to the USPS to reason if there was a non-discriminatory reason to do so; the USPS did so by proving the importance of Sunday Amazon delivery due to their poor financial situation. The burden shifted back to the plaintiff to prove a pretext, which he failed to do. Therefore, the court rejected his first argument.
409:
Groff continued to be absent from his scheduled work on
Sundays after the 2017 peak season and consequently was punished, so he filed a complaint asking USPS to transfer him to a job that did not require him to work on Sundays. This complaint was promptly denied as no position in the USPS had such an
549:
cost" in providing religious accommodation "does not suffice to establish undue hardship." This ruling places additional onus on the employer to prove that the burden placed on them to accommodate an employee's religious needs is "substantial in the overall context of an employer's business" to deny
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test for a "significant difficulty or expense standard" test, similar to the one in the ADA, to be the right decision and signalled to
Congress to make that decision themselves. Lastly, she clarified that burdens on co-workers may be undue hardship. She explained that animus towards co-workers and
405:
at
Holtwood offered to allow Groff to pray on Sunday morning before returning to work later in the day, but he declined the offer. In the peak season of 2017, another RCA volunteered to take over his shifts on Sunday, but that worker fell ill, leaving the rest of the RCAs and the postmaster to be
335:" are not sufficient to demonstrate "undue hardship", and that the onus is on the employer to demonstrate that granting the exemption would incur "substantial increased costs" compared to the normal costs of business. This decision has been widely praised by religious organizations.
168:(2) Whether an employer may demonstrate "undue hardship on the conduct of the employer's business" under Title VII by showing that the requested accommodation burdens the employee's co-workers as opposed to the business entity.
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The MOU did not provide Groff with a religious exemption to working on
Sundays and as a result, the USPS again moved to accommodate him by transferring him to a smaller station that did not fulfill Amazon deliveries, the
432:
In his first argument, Groff argued that he had direct evidence that the USPS discriminated against him. Nevertheless, the court found the evidence provided by Groff against the USPS to be insufficient. Therefore, the
577:, Justice Sotomayor wrote that for many years the EEOC had already been interpreting the "undue hardship" to be on the conduct of the company's business. She also added that the court's decision to not overrule the
524:
On June 29, 2023, the
Supreme Court ruled 9–0 for Groff, remanding the case back to the Third Circuit. Justice Alito wrote the opinion, Justice Sotomayor filed a concurring opinion which Justice Jackson joined.
389:
only allowed the exemption of work on Sunday on two conditions: (1) if the person had applied for leave on that day, and, (2) if the person would have exceeded the limit of 40 hours of work that week on Sunday.
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Title VII requires an employer that denies a religious accommodation to show that the burden of granting an accommodation would result in substantial increased costs in relation to the conduct of its particular
457:, the court rejected the argument, saying that the employer does not need to entirely rectify the conflict to accommodate and they do not need to accommodate the request due to Groff's request adding an
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things like coordinating voluntary shift swaps are not undue hardship, but clarified that effects on co-workers can still be "undue hardship" to the employer.
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557:(ADA) to compel companies to accommodate an employee's religious exemption from work, and conversely, the United States argued that
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Both parties' elaborations of their test, where Groff argued that lower courts should follow the jurisprudence under the
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for "undue hardship" was irreconcilable with the text and congressional purpose of Title VII, asking the court to grant
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was "basically correct", were found by the court to be "too far" and were squarely rejected.
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on the company. The court added that satisfying the demands by the petitioner is more than a
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Similarly to
Quarryville, Holtwood also started Sunday Amazon deliveries in March 2017. The
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Groff eventually resigned in 2019 and sued the USPS for two reasons, alleging he was "
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in support of the plaintiff, on
September 26, 2022, arguing that the standard set in
327:. The case was decided unanimously for Groff by the Court. While generally upholding
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was used, which placed the burden on the plaintiff, Groff, to show that there was a
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Religion and business § Landmark United States
Supreme Court cases
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541:. The ruling states that "undue hardship is very different from
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on January 13, 2023, and heard oral argument on April 18, 2023.
331:, the court clarified that increased costs that are more than "
323:" in making the accommodation, a vague phrase at the center of
315:(1977) had established that an employer could deny an employee
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162:-cost test for Title VII religious accommodations stated in
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additionally burdened to take over delivery on Sundays.
154:(1) Whether this Court should disapprove its more-than-
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United States Supreme Court cases of the Roberts Court
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United States Court of Appeals for the Third Circuit
429:, arguing that the USPS discriminated against him.
619:"Young Israel Praises Supreme Court's Decision in
915:United States employment discrimination case law
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497:Fifteen Republican members of Congress filed an
650:"U.S. bishops praise Supreme Court's unanimous
545:" and that an employer even "showing more than
533:The opinion clarified Title VII's standard of "
374:contracted the USPS to deliver their packages.
920:Religious discrimination in the United States
387:National Rural Letter Carriers' Association
485:Groff then filed a petition for a writ of
925:United States Postal Service litigation
559:Equal Employment Opportunity Commission
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892:
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751:– via Casetext Search + Citator.
715:– via Casetext Search + Citator.
468:Trans World Airlines, Inc. v. Hardison
355:(USPS) from 2012 until 2019. He is an
312:Trans World Airlines, Inc. v. Hardison
164:Trans World Airlines, Inc. v. Hardison
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297:, 600 U.S. 447 (2023), was a
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702:, Civil Action No. 19-1879"
654:religious freedom decision"
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381:However, in May 2016, a
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351:(RCA), working for the
349:Rural Carrier Associate
474:Groff appealed to the
343:Gerald E. Groff was a
247:Ketanji Brown Jackson
45:Decided June 29, 2023
43:Argued April 18, 2023
824:www.supremecourt.gov
659:Catholic News Agency
529:Opinion of the Court
438:burden shifting test
361:Protestant Christian
317:religious exemptions
126:, No. 5:19-cv-1879 (
109:Opinion announcement
105:Opinion announcement
820:"Docket for 22-174"
149:Questions presented
54:Gerald E. Groff v.
575:concurring opinion
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436:McDonnell Douglass
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376:Quarryville
357:evangelical
329:Trans World
271:Concurrence
223:Elena Kagan
56:Louis DeJoy
894:Categories
799:SCOTUSblog
605:References
547:de minimis
543:de minimis
539:de minimis
519:certiorari
511:certiorari
487:certiorari
463:de minimis
403:postmaster
339:Background
333:de minimis
67:Docket no.
370:In 2013,
265:unanimous
179:business.
77:Citations
847:Text of
804:June 29,
586:See also
579:Hardison
563:Hardison
506:Hardison
446:case of
396:Holtwood
260:Majority
128:E.D. Pa.
95:Argument
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160:minimis
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