The U.S. Supreme Court has agreed to hear the case of Groff v. DeJoy, an appeal from the U.S. Court of Appeals for the Third Circuit. In this case, the Court will consider what types of religious accommodations are reasonable without constituting an undue hardship on an employer’s business.
Gerald Groff is a former postal worker who sued the U.S. Postal Service (USPS) for failing to accommodate his observance of the Sunday Sabbath as a Christian. The USPS signed a contract with Amazon in 2013 to deliver packages, including on Sundays. In 2016, the USPS entered a collective bargaining agreement with the National Rural Letter Carriers’ Association to establish the process for scheduling carriers to make Sunday and holiday deliveries.
After the contract went into effect, the postmaster advised Groff that he would have to deliver packages on his scheduled Sundays. As a result, Groff transferred to another post office that had yet to implement the Sunday deliveries. That location then began Sunday deliveries. Groff then faced progressive discipline for not working on Sundays when scheduled, including a written warning and two suspensions. Ultimately, Groff missed at least 24 scheduled Sunday shifts and resigned.
The U.S. District Court for the Eastern District of Pennsylvania held that exempting Groff from the Sunday delivery schedule, as a religious accommodation, constituted an undue burden on the USPS. The accommodation would require Groff’s co-workers to work extra Sunday shifts and might require the USPS to violate the collective bargaining agreement with workers. The U.S. Court of Appeals for the Third Circuit agreed, finding that the accommodation disrupted the scheduled workflow and negatively affected employee morale.
To prove religious discrimination, an employee must prove that they hold a sincere religious belief that conflicts with a job requirement. In addition, the employee must inform the employer of the conflict and receive discipline for failing to complete the job requirement.
If the employee meets their initial burden, the employer must show that it either made a good-faith effort to accommodate the employee’s religious belief, or they must show that doing so would constitute an undue hardship on its business. Undue hardship is more than ordinary administrative costs on business operations, and it could include the cost of hiring another worker or paying a significant amount of overtime.
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