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Supreme Court strengthens religious rights at work: what Groff v. DeJoy means for you

Friday, June 30, 2023

Did the Court's decision go too far in affecting co-workers?

Supreme Court strengthens religious rights at work: what Groff v. DeJoy means for you

On June 29, 2023, the U.S. Supreme Court unanimously made it much harder for employers to deny religious accommodations on the job. In Groff v. DeJoy, the Court unanimously ruled in favor of a postal worker who didn’t want to work on Sundays because of his Christian faith. The decision was based on Title VII of the Civil Rights Act of 1964. The Court ruled that employers must make greater efforts to accommodate workers’ religious beliefs—even if that means bearing more cost or inconvenience.

While the decision may be good news for employees of all faiths, it also raises new questions and concerns about how far those protections should go—and what they might mean for co-workers and workplace fairness.


What was Groff v. DeJoy about?

Gerald Groff is an evangelical Christian who believes Sunday is a day of rest and worship. When he took a job with the U.S. Postal Service, the Service did not deliver on Sundays. But that changed when USPS started delivering Amazon packages. Groff requested that he not be required to work Sundays. At first, his managers tried to accommodate him. But later, they said they couldn’t do so anymore.

Groff faced discipline and eventually quit. He sued, alleging the Postal Service failed to reasonably accommodate his religious beliefs—as federal law requires.

The law at issue is Title VII of the Civil Rights Act of 1964. It says employers must accommodate workers’ religious practices unless doing so would cause an “undue hardship” on the business.

For decades, courts interpreted “undue hardship” to mean any more than a “de minimis” (small) cost or burden. This was based on the 1977 Supreme Court case Trans World Airlines v. Hardison. That weak standard often gave employers a lot of discretion to deny accommodations.


What did the Supreme Court decide?

The Supreme Court ruled that the old “more than a de minimis cost” standard was too weak and misread the law. Instead, the Court said that employers must show a “substantial increased cost in relation to the conduct of its particular business” before they can deny a religious accommodation.

This is a meaningful shift. It raises the bar for employers who want to deny religious accommodations.

Simply put, employers can’t just claim any inconvenience or cost to avoid accommodating your religious beliefs. They need to prove it would truly disrupt their business in a significant way.


Why this ruling matters

  • It affords workers greater protection for exercising their religious beliefs. Congress passed Title VII’s protection for religion to protect religious freedom at work. For years, courts watered down that protection. The Groff decision provides stronger protection to individual workers.
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  • It applies to all faiths—at least in theory. Whether you’re Hindu, Buddhist, Sikh, Jewish, Muslim, Christian, or of any other faith—or if your beliefs are less well-known—this ruling should help you. Employers must now take your religious practices more seriously. But it remains to be seen if employers and courts will really accommodate minority religious beliefs.

  • It may encourage better workplace policies. Employers may need to re-think how they handle requests for schedule changes, dress-code (including uniform) exemptions, time off for religious observance, and other workplace rules that affect people’s religious practices. They must take such requests seriously. That could mean more flexible and respectful workplaces for everyone. Employers can’t deny requests just because they are somewhat inconvenient or unpopular. Denials must be based on “substantial increased cost.”

  • Litigation. The decision will likely lead to more requests and possibly more lawsuits if accommodations are denied.

  • Co-worker impact. In Groff’s case, other employees had to work more Sundays to cover his absences. Under the new standard, it remains unclear how much impact on co-workers counts as a “substantial” cost. The decision could lead to religious accommodations that shift burdens unfairly onto others—particularly in small teams or already strained workplaces.

Proceed with caution

The Supreme Court’s Groff v. DeJoy decision strengthens the rights of religious employees. If you’ve been denied a religious accommodation at work—or if your employer made it too hard to follow your faith—this decision gives you stronger legal ground.

But while the Court rightly restored stronger protections for religious freedom, the ruling leaves a lot unanswered. What if one worker’s religious observance regularly conflicts with others’ rights or responsibilities? Or even conflicts with others’ religious beliefs? What if accommodating a belief places stress on an already overworked team?

These are not hypotheticals. They’re real-world consequences that courts—and employers—will now have to navigate, likely through further litigation. This decision will start to test where lines should be drawn.


At Chandra Law, we have handled cases involving religious discrimination and religious accommodation. Religious discrimination by a public employer or public entity might also violate the First Amendment. We have experience litigating First Amendment cases as well. If you believe your employer has violated your rights, we’re here to help.


Please contact us if you believe you have a case.

At Chandra Law, your case is our cause®.

Related Practice Areas
Employment DiscriminationEmployment RetaliationFirst AmendmentReligious DiscriminationFirst Amendment Retaliation
Tags
title-viireligious-accommodationreligious-discriminationfreedom-of-religiontitle-vii-retaliation

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