Meta description: Learn how Groff v. USPS changed the Title VII religious accommodation standard, what “substantial increased costs” means, and how employers and workers can respond.
The Supreme Court’s 2023 decision in Groff v. DeJoy reshaped how U.S. employers evaluate requests for religious accommodation under Title VII. The ruling clarified that employers cannot reject an accommodation simply because it creates a minor cost or inconvenience. Instead, they must show that granting it would cause substantial increased costs in relation to the conduct of their particular business. The decision affects workplace scheduling, Sunday work, staffing, and the way employers and employees discuss religious needs.
What Was Groff v. USPS About?
Gerald Groff worked for the U.S. Postal Service as a rural carrier associate in Pennsylvania. He was an evangelical Christian who believed he should not work on Sundays. When USPS began delivering packages for Amazon on Sundays, Groff sought to avoid Sunday shifts.
USPS initially tried to accommodate him through arrangements that included asking other employees to cover his shifts and transferring him to a different station. Those measures did not resolve the scheduling issue. Groff received discipline after missing Sunday work and eventually resigned.
Groff sued USPS, alleging that it failed to provide a reasonable religious accommodation as required by Title VII of the Civil Rights Act of 1964. Lower courts ruled for USPS, applying the long-standing standard associated with the Supreme Court’s 1977 decision in Trans World Airlines, Inc. v. Hardison. The Supreme Court agreed to clarify what that standard means.
The Supreme Court’s Decision
On June 29, 2023, the Supreme Court unanimously ruled in Groff v. DeJoy, 600 U.S. 447 (2023). Justice Samuel Alito wrote the opinion. The Court held that an employer claiming undue hardship must show that the proposed accommodation would result in substantial increased costs in relation to the conduct of its particular business.
The Court rejected the interpretation that an employer can deny an accommodation whenever it would impose anything more than a minimal cost. It explained that the often-cited “de minimis” language from Hardison had been read too broadly. The Court did not discard Hardison altogether; it clarified the standard under Title VII.
The case was sent back to the lower courts to apply the clarified test to the evidence. The Supreme Court did not decide that Groff was automatically entitled to his requested accommodation, nor did it rule that USPS had violated Title VII. The decision focused on the legal standard for determining undue hardship.
How Title VII Religious Accommodation Works
Title VII generally prohibits employers from discriminating against employees because of religion. It also requires covered employers to reasonably accommodate an employee’s sincerely held religious beliefs, practices, or observances unless the employer can demonstrate undue hardship.
A religious accommodation is a workplace adjustment that helps an employee observe or practice their religion. The need may involve a schedule, dress or grooming, religious expression, or another workplace policy. An employee does not have to use legal terminology or submit a formal written request to raise a religious accommodation need, though written documentation can help clarify the request.
The law does not require an employer to grant the employee’s preferred accommodation if another effective option is available. The employer and employee can discuss alternatives. The central questions are whether the accommodation addresses the religious conflict and whether providing it would create undue hardship under the standard clarified in Groff.
What “Substantial Increased Costs” Means
The Court said undue hardship must be assessed in the context of the employer’s particular business. A cost that is substantial for one employer may not be substantial for another. The analysis is fact-specific and considers the nature, size, and operating circumstances of the business.
Costs are not limited to direct financial expenses. Relevant effects may include operational burdens, staffing challenges, or impacts on the employer’s ability to conduct its business. But the employer must connect those effects to the accommodation and show that they amount to substantial increased costs in context. A vague claim that an accommodation is inconvenient is not enough by itself.
The Court also addressed effects on coworkers. Coworker resentment, religious hostility, or dislike of an employee’s beliefs cannot alone establish undue hardship. However, the practical effects of an accommodation on coworkers may be relevant when they affect the conduct of the business—for example, if repeated coverage requirements cause meaningful operational disruption or substantial additional costs.
The distinction is important: the law does not require employers to ignore genuine operational consequences, but it does require more than relying on coworkers’ objections or minor inconvenience. Employers need to evaluate actual effects rather than assume that any scheduling adjustment is too burdensome.
Examples of Religious Accommodation Requests
Religious accommodation can arise in many workplaces, not only when an employee requests Sundays off. The appropriate response depends on the specific job, the employee’s religious practice, and the employer’s operations.
- Scheduling: An employee requests time off for a Sabbath, weekly worship, or a religious holiday.
- Shift swaps: An employee asks to exchange a shift or use a voluntary shift-trading system to avoid a religious conflict.
- Breaks: An employee requests a brief break at a particular time for prayer or another religious observance.
- Dress or grooming: An employee seeks permission to wear religious clothing, a head covering, jewelry, or facial hair that conflicts with a workplace rule.
- Job duties: An employee asks for an adjustment to a task that conflicts with a sincerely held religious belief.
These examples do not guarantee that a particular request must be granted in a specific form. Employers may consider workable alternatives, and they may deny an accommodation if they can establish undue hardship under Title VII’s clarified standard.
What Changed for Employers After Groff v. DeJoy?
The decision calls for a more careful, evidence-based review of religious accommodation requests. Employers should not treat a small administrative burden, routine schedule adjustment, or coworker complaint as an automatic reason for denial.
A sound process typically begins by understanding the religious conflict and the adjustment being requested. The employer can then explore possible accommodations, assess effects on staffing and operations, and document the basis for its decision. If the preferred option presents a problem, proposing an effective alternative can help keep the discussion constructive.
Employers should also apply workplace rules consistently. A policy that allows schedule changes for some reasons but rejects comparable religious requests may raise concerns, depending on the facts. Consistency does not mean every request must receive identical treatment; it means decisions should be grounded in relevant business considerations rather than stereotypes or hostility toward religion.
Documentation can be useful. Employers may record the request, the alternatives considered, relevant staffing or cost information, and the reasons a particular option would or would not work. The goal is not to create paperwork for its own sake, but to show that the decision reflects an individualized assessment.
What Employees Can Do When Requesting Accommodation
Employees can help start the process by explaining the religious practice that creates a workplace conflict and the adjustment that may address it. A request need not cite Title VII or Groff v. USPS. It may be made verbally, although written communication can reduce misunderstandings.
If the employer cannot provide the requested arrangement, employees can ask whether another option is available. For a scheduling conflict, possible alternatives might include a shift exchange, a different schedule, or use of an existing leave or scheduling policy. Whether any option is reasonable depends on the circumstances.
Employees should keep copies of relevant communications and note important conversations, dates, and proposed alternatives. If a request is denied, they can ask for the specific operational reason and whether other accommodations were considered. These steps do not guarantee a particular outcome, but they can clarify the employer’s reasoning and preserve useful information.
Employees who believe they have experienced religious discrimination may consult the U.S. Equal Employment Opportunity Commission (EEOC), a state or local fair-employment agency, or an employment attorney. Filing deadlines and procedures can vary, so people considering a complaint should check the applicable rules promptly.
What the Ruling Does Not Require
Groff v. DeJoy did not eliminate the undue-hardship defense or require employers to grant every religious request. An employer may still deny an accommodation when it can demonstrate substantial increased costs in relation to the conduct of its particular business.
The ruling also does not mean that every employee must receive a schedule change, that all coworker impacts are irrelevant, or that an employee’s preferred solution must be selected. Instead, it requires a closer examination of the facts and the accommodation’s actual effects.
Nor does the decision make an employee’s sincerity or religious claim a subject for casual judgment. Employers generally should focus on understanding the accommodation need and evaluating workable options, rather than demanding that a belief fit a familiar religious tradition. Questions about sincerity or the nature of a request should be handled carefully and consistently with applicable law.
How Groff Fits Into Workplace Scheduling
Scheduling is one of the most common settings for religious accommodation disputes because employers must balance employee availability with coverage, customer needs, and deadlines. The ruling makes clear that a scheduling policy is not automatically decisive: employers must still consider whether an effective accommodation is possible without substantial increased costs.
In a small workplace with limited staff, a recurring shift change might create a different operational impact than it would at a large organization with multiple employees available to cover the work. The employer’s business model, staffing arrangements, frequency of the request, and available alternatives may all matter. The standard is contextual rather than a one-size-fits-all formula.
That does not mean employers must permanently transfer all burdens to other employees. A relevant question is whether the proposed arrangement would create substantial costs or meaningful disruption to the business. Evidence about coverage, overtime, service levels, and the availability of alternatives may help explain the practical effects.
Why the Decision Matters Beyond USPS
Although the case involved the Postal Service and Sunday package delivery, its legal standard applies broadly to Title VII religious accommodation claims involving covered employers. It is relevant to workplaces where schedules, uniforms, grooming rules, or job duties may conflict with religious practices.
The ruling also changes how earlier references to the “de minimis” test should be understood. Employers, employees, and HR professionals should avoid treating that phrase as the current rule. The governing question is whether the accommodation would impose substantial increased costs in relation to the conduct of the particular business, assessed using the relevant circumstances.
For employers, the practical message is to engage with requests rather than dismiss them based on minor inconvenience. For employees, it is that Title VII provides meaningful protection, but the law still requires a case-specific evaluation and does not guarantee a particular accommodation. The Supreme Court’s clarification makes the process more demanding and more fact-based for everyone involved.
Key Takeaways From Groff v. USPS
- The Supreme Court clarified the Title VII undue-hardship standard in Groff v. DeJoy in 2023.
- An employer must show that an accommodation would cause substantial increased costs in relation to the conduct of its particular business.
- Minor costs or inconvenience alone do not automatically justify denying a religious accommodation.
- Coworker effects matter when they affect business operations, but coworker hostility or resentment alone is not undue hardship.
- Employers and employees can consider alternatives; the employee’s preferred option is not necessarily the only reasonable solution.
- The decision requires an individualized assessment and does not automatically guarantee any requested accommodation.