The U.S. Supreme Court unanimously ruled in favor of a Christian postal worker who faced disciplinary action from his employer for refusing to work on Sundays due to religious reasons. The court's decision in Groff v. DeJoy, written by Justice Samuel Alito, clarified that an employer must demonstrate substantial increased costs to deny a religious accommodation requested by an employee under federal law. The ruling rejected the previous "de minimis" interpretation of the "Hardison Standard" established in the 1977 case TWA v. Hardison, which allowed employers to deny religious accommodation if it posed more than a trivial cost. The Supreme Court's decision marks a reversal of that interpretation.
In the case of Groff v. DeJoy, Justice Samuel Alito clarified that the previous "de minimis" interpretation of the Hardison Standard had led to insufficient attention being paid to the actual text of Title VII regarding religious accommodation. The Supreme Court emphasized that "undue hardship" should be understood according to its plain meaning and that courts should use a commonsense approach to assess whether a hardship would be substantial for an employer's business.
Alito specified that the impact on coworkers should only be considered to the extent that it affects the conduct of the business, and bias or hostility toward religion should not be a factor in deciding whether to grant a religious accommodation request. If bias or hostility were considered a defense to a reasonable accommodation claim, it would contradict the principles of Title VII.
Furthermore, the Supreme Court rejected the de minimis interpretation and remanded Groff's case to the lower courts for examination under the newly clarified standard. The lower courts will apply the context-specific standard and determine if further factual development is necessary.
Gerald Groff, an evangelical missionary and former postal worker, was at the center of this case. He alleged that he faced harassment, targeting, and disciplinary action from the U.S. Postal Service (USPS) for refusing to work on Sundays in order to honor the Third Commandment.
In 2019, Groff resigned from his position and filed a lawsuit against the USPS, claiming a violation of his religious rights. However, his claims were initially denied by a Pennsylvania district court and later by the 3rd Circuit Court. In January, the Supreme Court agreed to hear Groff's appeal.
The Supreme Court's decision in this case is anticipated to have significant implications for the religious rights of employees nationwide.
According to Becket, a religious liberty law firm, the Hardison precedent has resulted in the denial of 86% of workplace religious accommodation requests. The firm argues that this test has been used by large companies to reject even basic religious accommodations, particularly for employees with minority religious beliefs.
Becket President Mark Rienzi hailed the Supreme Court's ruling as a victory for individuals who want to live and work in accordance with their religious beliefs. He stated that the decision ensures that hardworking religious Americans no longer have to choose between their job and their faith.
The First Liberty Institute, which represented Gerald Groff in this case, celebrated the ruling as a "landmark victory" for workers across the country. They asserted that no American should be forced to make a choice between their faith and their job. The institute believes that the decision strengthens legal protections for employees seeking religious accommodations and will have an impact on every workplace with at least 15 employees nationwide.
In a video statement, Gerald Groff expressed his honor at being part of a case that is expected to have a positive impact on millions of Americans.