On June 29, 2023, the US Supreme Court issued a decision clarifying the standard employers must apply in considering an employee’s religious accommodation request under Title VII of the Civil Rights Act. In Groff v. DeJoy , the justices unanimously ruled that Title VII requires employers who deny such requests to demonstrate that granting the request would result in “substantial increased costs in relation to the conduct of its particular business.” Under this heightened standard, it will be more difficult for employers – who have historically relied on a less burdensome “more than a de minimis cost” standard – to deny religious accommodation requests. Case background Gerald Groff, an evangelical Christian and former postal worker with the United States Postal Service (USPS), adhered to a religious belief that Sundays must be devoted to worship and rest. Accordingly, when USPS required him and co-workers to deliver packages on Sundays, he sought a religious accommodation to avoid working on Sunday. Although USPS redistributed some of Groff’s Sunday shifts to other staff, it denied fully granting his requested accommodation on the basis that it would impose an undue hardship. Groff was subject to progressive discipline for failing to work on Sundays, leading […]
