At the center of the case is Gerald Groff, a former U.S. Postal Service employee who wanted to take Sundays off for church and rest. That presented a scheduling conflict – and a burden on his colleagues, the government argued – after the Postal Service started delivering Amazon packages on Sundays.
The decision could affect other situations where religion and workplace rules conflict, such as for religious dress. Some worried the case could also affect religious conduct at work, giving employees (and employers) more leeway to exercise their personal views even if they were inconsistent with those held by their employers or colleagues.
A U.S. District Court and the Philadelphia-based U.S. Court of Appeals for the 3rd Circuit sided with the Postal Service.
It was a unanimous decision.
The Supreme Court threw out that “de minimus” standard and clarified when workers’ religions can’t be accommodated, saying workplaces must instead show that the accommodation would “result in substantial increased costs in relation to the conduct of its particular business.”
Employers must “reasonably accommodate” workers’ religions and not just “assess the reasonableness of a particular possible accommodation or accommodation,” the court ruled, meaning an employer couldn’t just “conclude that forcing other employees to work overtime would constitute an undue hardship” in a case like Groff’s.
The court sent Groff’s case back to the lower court, which will now decide based on the new standard if the USPS acted unlawfully by requiring him to work on Sundays.
While the court ruled to redefine undue hardship, its opinion does not present a clear victory for Groff. His case was returned to a lower court for reconsideration in light of the Supreme Court’s clarification.
U.S. Court of Appeals for the Third Circuit previously wrote in their decision:
Exempting Groff from working on Sundays caused more than a de minimis cost on USPS because it actually imposed on his coworkers, disrupted the workplace and workflow, and diminished employee morale at both the Holtwood Post Office and the Lancaster Annex hub. The Holtwood Post Office to which Groff was assigned had only a postmaster and three RCAs (Rural Carrier Associate) (including Groff) available for Sunday deliveries. Because Groff would not work on Sundays, only three individuals remained who could work on Sundays during the peak season. After the one RCA who covered for Groff was injured, only the Holtwood Postmaster and the remaining RCA were available to work the Sunday shift. This placed a great strain on the Holtwood Post Office personnel and even resulted in the Postmaster delivering mail on some Sundays. The Holtwood Postmaster testified, “[o]ther carriers were being forced to cover [Groff’s] shifts and give up their family time, their ability to attend church services if they would have liked to,” and these additional demands “created a tense atmosphere with the other RCAs.” JA464.
