## Facts

- Gerald E. Groff, a USPS rural carrier associate, held a religious belief requiring Sunday worship and rest.
- After USPS began facilitating Sunday package delivery, Groff sought to avoid Sunday shifts and transferred to a station that initially did not have Sunday deliveries.
- When Sunday deliveries later began at that station, Groff continued to decline Sunday work for religious reasons.
- USPS attempted to cover Groff’s Sunday work by arranging for other employees to take his deliveries.
- USPS imposed progressive discipline for Groff’s failure to work scheduled Sundays, and Groff ultimately resigned.
- Groff sued under Title VII, alleging USPS could have accommodated his Sunday observance without undue hardship on the conduct of its business.

## Issues

1. What standard governs “undue hardship on the conduct of the employer’s business” under Title VII’s religious-accommodation provision.
2. Whether the “more than de minimis cost” formulation associated with prior precedent correctly states Title VII’s undue-hardship standard.

## Decision

- The Supreme Court unanimously held that an employer denying a religious accommodation must show the accommodation would cause “substantial increased costs in relation to the conduct of its particular business.”
- The Court rejected treating “more than de minimis cost” as the controlling undue-hardship standard.
- The Court vacated the Third Circuit’s judgment and remanded for further proceedings under the clarified standard.
- The Court did not decide whether USPS met the standard on Groff’s record, emphasizing a fact-specific inquiry.
- A concurrence agreed with the clarified standard and stressed continuity with prior precedent, including limits where accommodations would conflict with neutral systems such as seniority arrangements.

## Legal Principles

- Under Title VII, “undue hardship” requires a showing of substantial increased costs relative to the employer’s particular business, not merely a minimal burden.
- Courts must evaluate all relevant circumstances, including the requested accommodation’s practical impact in light of the employer’s operations, size, and operating costs.
- Coworker impacts matter only to the extent they translate into effects on the conduct of the business; religious hostility or animus cannot establish undue hardship.
- The inquiry is accommodation-specific; employers must tie asserted hardships to the requested accommodation and to business-related costs or operational burdens.

## Conclusion

The Court clarified that Title VII permits denial of a religious accommodation only when the employer proves the accommodation would impose substantial increased costs in relation to its business, and it sent the case back for application of that standard to the facts.


Groff v. DeJoy, 600 U.S. 447 (2023)