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SCOTUS “Groff Opinion” Another Win for Religious Liberty

united states postal service van

In the last week of June, the United States Supreme Court issued a number of key opinions as its “2022 term” came to a close. Much attention was given to the divided ruling in 303 Creative v. Elenis, which found that Christian website designer Lorie Smith could not be forced by the State of Colorado to create websites and “speech” that violated her First Amendment rights. Another important win, the case of Groff v. DeJoy received less attention, but also marked a major victory for religious liberty.

In this case, the Supreme Court unanimously ruled in favor of Gerald Groff, an Evangelical Christian who resigned from his job with the United States Postal Service (USPS) because he sought to honor the Sabbath by not working on Sundays. When he began work with the USPS in 2012, Groff was able to arrange his schedule to have Sundays off, but several years later the USPS began delivering packages for Amazon, which required Sunday deliveries. Although some accommodations were made, Groff continued to receive “progressive discipline” for failing to work Sundays and ultimately resigned his job in 2019.

The opinion began by stating: “Title VII of the Civil Rights Act of 1964 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.’” The question before the Court essentially revolved around what the USPS had to prove in order to legally deny Groff a religious accommodation.

Important Ruling

The Justices were undivided in their view about what employers must show to deny religious accommodations. Clarifying a rule from a previous case, the Court explained exactly what is meant by “undue hardship,” and said that employers have to show “more than a de minimis cost” in order to deny an employee a religious accommodation.

Title VII Clarified

Looking at Title VII, the Court focused on the language of “undue hardship,” which it defined as accommodations that “would result in substantial increased costs in relation to the conduct of its particular business.” Importantly, the Court ruled out certain situations that cannot be used to suggest undue hardship and deny a religious accommodation, such as a “coworker’s dislike of religious practice and expression in the workplace.”

The Groff opinion was a major win for religious liberty. To learn more information about Groff v. DeJoy, visit our friends at First Liberty Institute who represented Gerald Groff in this case.


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