Civil Rights & Constitutional Law
Norse Pagan Heathen fired for rejecting employer’s ultimatum to shave beard
October 22, 2018
Friday, June 30, 2023
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.
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.
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.
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.
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