In a unanimous 9-0 decision, the Supreme Court sided with a Christian postal worker who refused to work on Sundays due to his religious beliefs. This landmark case reestablishes civil rights protections for Christian workers.
Gerald Groff began working for the USPS in 2012, before mail was distributed on Sundays. The next year, USPS reached an agreement with Amazon to deliver packages on Sundays, and in 2016 the corporation gained the approval of the postal worker union in establishing how the additional work would be distributed.
Seeing the writing on the wall, Groff requested a transfer to a rural post office that did not make deliveries on Sundays. That only lasted for so long, as Sunday deliveries became common practice across the nation. When the rural post office also began requiring their workers to take Sunday shifts, Groff was initially successful in gaining accommodation by switching shifts with coworkers. However, whenever he could not manage to find a substitute worker, he was faced with “progressive discipline” for failing to report to work on Sundays. In 2019, Groff resigned his position because his religious convictions were not being accommodated by the USPS.
Shortly after, Groff sued the USPS under Title VII of the Civil Rights Act of 1964 which “requires employers to accommodate the religious practice of their employees unless doing so would impose an ‘undue hardship on the conduct of the employer’s business.’” In his case, Groff asserts that the “USPS could have accommodated his Sunday Sabbath practice ‘without undue hardship on the conduct of [USPS’s] business.’” Thus, refusing to provide religious accommodations was a violation of Groff’s civil rights.
The district and circuit court levels ruled against Groff based on their standard from a previous case known as “de minimis” – a Latin phrase meaning something too trivial or minimal to merit consideration. If providing religious accommodation to an employee would require more than “minimal consideration,” a company is not required to grant the request. This standard ignored the original intent of the protections guaranteed by the Civil Rights Act, and it took the Supreme Court to reestablish the protections Congress envisioned.
“This is a great moment for America, for religious freedom,” Groff commented on the SCOTUS ruling. “I’m just overjoyed [to] be a part of this moment. And just to rejoice that no one else should have to go through what I have … now that the court has spoken.”
The 9-0 decision firmly established that companies are required to grant religious accommodation to employees if it would not require “undue hardship on the conduct of the employer’s business” – that is, impose a substantial burden on the business. Inconvenience is not a valid excuse for denying someone’s request for religious accommodation.
“We’re in an era right now of growing secularism where people don’t understand the religious obligations [that] religious people have in the workplace,” Groff’s co-counsel, Randell Wenger, said. “And so employers are asking for more and more, not really understanding the impossibility that creates for a religious employee like Gerald, [for whom] this isn’t just an issue of, ‘Hey, I’ve got a preference to not work on Sunday.’ It’s ‘I can’t work here unless you make a way for me to do this because I’ve got a religious conviction.’ And so the standard is going to make it a whole lot easier for employees to follow their convictions and not have to give up their jobs.”