Groff v. DeJoy, Postmaster General

Summary

The Supreme Court interpreted Title VII’s requirement that employers reasonably accommodate employees’ religious practices unless doing so would impose an undue hardship. The Court rejected the view that any cost more than de minimis establishes undue hardship and held that an employer must show that granting an accommodation would result in substantial increased costs in relation to the conduct of its particular business. The Court vacated the Third Circuit’s judgment and remanded for application of the clarified standard.

Holdings

1. An employer denying a religious accommodation must show that the burden of granting the accommodation would result in substantial increased costs in relation to the conduct of the employer's particular business. A burden that is merely more than de minimis is insufficient.
2. Courts must consider all relevant factors in the particular case, including the accommodation requested and its practical impact in light of the nature, size, and operating cost of the employer.
3. Impacts on coworkers are relevant only to the extent they affect the conduct of the employer's business. Employee animosity toward a religion, religious practice, or accommodation cannot constitute undue hardship.
4. Title VII requires an employer to reasonably accommodate an employee's religious practice, not merely assess the reasonableness of one proposed accommodation. The employer must consider other options when appropriate.
5. The Third Circuit's judgment could not stand because it applied the erroneous more-than-de-minimis standard; the clarified standard must be applied by the lower courts in the first instance.

Questions Presented

1. What standard governs whether an employer has demonstrated an undue hardship under Title VII when denying a religious accommodation?
2. Whether the undue-hardship inquiry may consider impacts on coworkers and, if so, whether those impacts must affect the conduct of the employer's business.
3. Whether an employer must consider other reasonable accommodations rather than merely determine that one proposed accommodation would impose an undue hardship.

Disposition

vacated