Groff v. DeJoy

Groff v. DeJoy, 600 U.S. 447 (2023), was a United States Supreme Court case regarding religious liberty and employment accommodations under Title VII of the Civil Rights Act of 1964.

Prior, Trans World Airlines, Inc. v. Hardison (1977) had established that an employer could deny an employee religious exemptions from work if they could show "undue hardship" in making the accommodation, a vague phrase at the center of Groff.

Groff was initially an RCA at the Quarryville post office and informed the USPS of his religious need and his inability to work on Sundays.

[4] The MOU did not provide Groff with a religious exemption to working on Sundays and as a result, the USPS again moved to accommodate him by transferring him to a smaller station that did not fulfill Amazon deliveries, the Holtwood post office.

The court added that satisfying the demands by the petitioner is more than a de minimis burden, as set forth by Trans World Airlines, Inc. v.

Fifteen Republican members of Congress filed an amicus brief in support of the plaintiff, on September 26, 2022, arguing that the standard set in Hardison for "undue hardship" was irreconcilable with the text and congressional purpose of Title VII,[5] asking the court to grant certiorari and overturn its precedent.

Both parties' elaborations of their test, where Groff argued that lower courts should follow the jurisprudence under the Americans with Disabilities Act (ADA) to compel companies to accommodate an employee's religious exemption from work, and conversely, the United States argued that Equal Employment Opportunity Commission's (EEOC) construction of Hardison was "basically correct", were found by the court to be "too far" and were squarely rejected.

In her 3-page concurring opinion, Justice Sotomayor wrote that for many years the EEOC had already been interpreting the "undue hardship" to be on the conduct of the company's business.