Groff, a former mail carrier for the United States Postal Service (USPS) and an observant Evangelical Christian, was subject to progressive discipline over several months because of his commitment to observing the Sunday Sabbath as a day dedicated to worship and rest. He ultimately left his job when it became clear that he would be terminated. His attempt at vindicating his right to a workplace accommodation was unsuccessful in the lower courts, which invoked the old “more than de minimis” standard in ruling that the USPS was permitted to deny Groff’s request to be exempted from Sunday work because of the resulting imposition on his coworkers, disruption to the workplace and its workflow, and diminishment of employee morale. Groff’s case will now return to the lower courts for reassessment under the new, more demanding standard. 

Amid some very high-profile decisions last week, the Supreme Court delivered an important win for religious freedom in the workplace. In Groff v. DeJoy, the Court eased the way for religiously observant employees to obtain accommodations from their employers that are necessary to allow them to live their beliefs. This unanimous decision written by Justice Alito swept aside what the Court characterized as a nearly 50-year-long misunderstanding about the requirements of Title VII and the holding of a 1977 decision called TWA v. Hardison, which lower courts have interpreted to allow employers to deny requests for religious accommodations that would result in any burden on the employer that is “more than … de minimis,” or minimal.
In Groff, the Court says that the reading of its prior holding has been wrong all along. Instead, an employer may deny an employee’s request for a religious accommodation only if “the burden of granting an accommodation would result in substantial increased costs in relation to the conduct of its particular business” (emphasis added).
The question presented by this case may seem like the kind of esoteric legal query – complete with obscure Latin terminology – that only a lawyer could love. What does it matter, one might ask, whether Title VII requires that an employer must show a more than de minimis burden or must meet some other standard before denying an employee’s request for a religious accommodation? It turns out it matters a great deal, as the facts of Gerald Groff’s case demonstrate.
Groff, a former mail carrier for the United States Postal Service (USPS) and an observant Evangelical Christian, was subject to progressive discipline over several months because of his commitment to observing the Sunday Sabbath as a day dedicated to worship and rest. He ultimately left his job when it became clear that he would be terminated.
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