In a unanimous decision issued Thursday, the United States Supreme Court has discarded decades-long precedent by strengthening legal protections for workers whose religious beliefs conflict with their job obligations. The ruling in Groff v DeJoy is expected to have a significant impact on job opportunities for Americans of various faiths who have frequently faced challenges due to their Sabbath-keeping practices. The Court’s decision will reshape how businesses offer religious accommodation under Title VII of the Civil Rights Act of 1964.
The case centered on Gerald Groff, a devout Christian whose faith prompts him to keep a 24-hour Sabbath on Sunday. Groff worked for the United States Postal Service (USPS), but faced ongoing difficulties in obtaining religious accommodation from his employer. Though initially accommodated by USPS, Groff’s repeated appeals for continued freedom to not work on his day of rest and worship were ultimately denied when the USPS signed contracts with Amazon, the massive retail and distribution company, for Sunday deliveries.
Despite his repeated requests to be exempted from working on Sundays, the USPS denied Groff’s requests, citing the previous precedent from Trans World Airlines, Inc. v Hardison (1977) that only required employers to suffer minimal hardship. This low threshold, referred to as a “de minumusstandard,” was often used to justify denying religious accommodations.
The Court’s opinion, written by Justice Samuel Alito, specifically addressed the “de minimus” standard, and insisted on a much more substantial reading of “undue hardship.” Alito wrote: “We think it is enough to say that an employer must show that the burden of granting an accommodation would result in substantial increased costs in relation to the conduct of its particular business.”
The legal team representing Groff included Adventist attorney Alan Reinach, who serves as Director of Public Affairs & Religious Liberty for the Pacific Union Conference of Seventh-day Adventists. During the appeals process, First Liberty, a prominent religious freedom advocacy group, joined the litigation team and recruited appellate counsel Aaron Streett from the law firm Baker Botts, LLP. The case was argued before the Court on April 18, 2023.
Speaking for the General Conference of Seventh-day Adventists and its North American Division, Todd McFarland, Deputy General Counsel, who also wrote the amicus brief filed by the church, said, “We are very pleased this morning that the Supreme Court took an important step towards protecting people of faith in the workplace. No one should have to choose between their job and their faith. Today’s decision reaffirms that employers cannot use an employee’s religious belief as an excuse to terminate them.”
A diverse group of faith-based and religious liberty organizations filed amicus briefs with the Supreme Court supporting Groff, including the General Conference of Seventh-day Adventists, The American Center for Law And Justice, The Sikh Coalition, the Union of Orthodox Jewish Congregations of America, the Council On American-Islamic Relations, The Church of Jesus Christ of Latter-day Saints, the American Hindu Coalition, the Becket Fund for Religious Liberty, and the Baptist Joint Commission.
Organizations opposing Groff’s petition to the Court included the AFL-CIO, the American Postal Workers Union, The Freedom from Religion Foundation, and the Center for Inquiry and American Atheists.
“Drawing on the 1977 case, employers only had to suffer a bare minimum amount of hardship to justify denying religious accommodation to an employee,” said Reinach. “This standard neutered the law and led to the termination of employment for literally thousands of Americans of all faiths. Seventh-day Adventists were especially harmed in that hourly wage workers are frequently assigned shift schedules including Sabbath hours.”
The Supreme Court's ruling in Groff v DeJoy not only acknowledged the unfair burden placed on workers with religious conflicts but also highlighted the need for a more robust approach to religious accommodation.
The ruling is expected to have far-reaching implications for workers across the country. By raising the standard for employers to justify denying religious accommodation, the Court's decision provides greater protection for employees with sincerely held religious beliefs. It sends a clear message that employers must make reasonable efforts to accommodate their employees' religious practices, even if it requires some degree of hardship.
The decision in Groff v DeJoy is seen as a significant victory for religious freedom advocates who have long argued for stronger legal protections. It marks a shift toward a more equitable approach that recognizes the importance of accommodating the diverse religious practices of American workers. As a result of this ruling, employees who face conflicts between their job requirements and their religious beliefs can expect increased opportunities to obtain reasonable accommodations from their employers.
Attorney Mitch Tyner, retired associate general counsel for the church and also a former Capitol Hill liaison, was both pleased and cautious about the Court’s decision. “First, kudos to Todd McFarland and team who finally got the court to right a wrong from fifty years ago,” Tyner said. “I spent more than 40 years working toward that end, and they were able to get the job done. That said, note that the opinion leaves lots of wiggle room for lower courts to decide what constitutes a substantial cost increase in each case. The Court has changed the recipe to be used to arrive at a correct decision. But remember, the ultimate proof is in the pudding, not in the recipe.”
As the ruling sets a new precedent for religious accommodation, it remains to be seen how rapidly employers will adapt their policies and practices. Further litigation to clarify the Supreme Court’s new thresholds is anticipated. It is clear, however, that this decision marks a significant milestone in protecting the rights of workers with religious conflicts.
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