On Thursday, the U.S. Supreme Court ruled unanimously in favor of a Christian postal worker who was fired for refusing to work on Sundays. The Court’s decision in Groff v. DeJoy, written by Justice Samuel Alito, overruled the Third Circuit Court of Appeals’ decision that the USPS did not violate Gerald Groff’s religious accommodation rights under Title VII of the Civil Rights Act.
“This decision will give those religious minorities a fair shot in court and, one would hope, encourage more employers to adopt more inclusive workplace policies so that religious employees won’t have to choose between their livelihood and their faith,” Joshua McDaniel, director of Harvard Law School’s Religious Liberty Clinic, said.
The Court clarified the rules of Title VII and sent the case back to the Third Circuit for retrial due to its factual complexity. It is possible that either Groff or the USPS may win, but the USPS and all employers must now meet a higher standard to refuse a religious accommodation.
Groff, a devoted Evangelical Christian who had been working for USPS for a long time, used to refrain from working on Sundays as per his job description and religious beliefs. However, when USPS entered into a partnership with Amazon to make Sunday deliveries, it started to demand that he work on his day of worship. To prevent any friction, he chose to relocate to a different location.
The man’s job location began delivering on Sundays. He did not want to work on Sundays due to his religious beliefs and claimed that the USPS punished him for this by using “progressive discipline”. Eventually, he resigned from his job and filed a lawsuit against USPS for discrimination based on his religion. However, the Third Circuit court did not agree with his claim.
The controversy in this case revolves around a standard that is 50 years old. The standard comes from Trans World Airlines v. Hardison. The Court stated that an employer could refuse to provide accommodation if it is more than a “de minimis cost.” Legally, this means that anything that costs more than a “very small” amount could be enough for an employer to deny any religious accommodation.
According to the Court’s decision, in order to deny a religious accommodation, employers must prove that it would cause a substantial burden on their business. Merely showing that the accommodation would result in a small cost is not sufficient to meet the “undue hardship” standard of Title VII.
“[Costs imposed on a business due to a religious accommodation] would have to rise to the level of hardship, and adding … ‘undue’ means that the … burden … or adversity must rise to an ‘excessive’ or ‘unjustifiable’ level,” Alito wrote. “When ‘undue hardship’ is understood in this way, it means something very different from … something that is ‘very small or trifling.’”
Justice Alito has pointed out that lower courts have been using a lenient standard from a previous case to reject many requests for minor accommodations based on religious beliefs. Becket Law, a firm that advocates for religious freedom, has reported that 86% of such requested accommodations under the now-inoperative de minimis test have been denied.
Some religious individuals have faced discrimination in the workplace for wearing clothing or hairstyles that are part of their religious beliefs. For example, Muslim women who wear hijabs, Apostolic Pentecostal women who prefer skirts over pants, and Sikh men who wear turbans and grow beards have all been denied these choices. Religious groups such as Orthodox Jews, Muslims, Sikhs, and Christians have filed briefs to support a decision that would provide more protection for religious accommodations in the workplace in the future.
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