No. 18-349October Term 2019Decided Feb 24, 2020
Darrell Patterson, Petitioner v. Walgreen Co.
The Supreme Court did not take up the case, so it did not resolve the Title VII accommodation questions raised in the petition.
Case status
- Current stage
- Decided
- Latest event
- Decision released Feb 24, 2020
- What it's about
from the United States Court of Appeals for the Eleventh Circuit.
Question presented
1. Whether Title VII may require an employer to provide a partial accommodation for an employee’s religious practices even if a full accommodation would impose an undue hardship? 2. Whether an employer can show that an accommodation would impose an undue hardship based on speculative harm?
- Case path
United States Court of Appeals for the Eleventh Circuit / Decision released Feb 24, 2020
- Area
Decided Supreme Court case
Briefing
What it's about
This case asked whether Title VII can require an employer to offer a partial religious accommodation when a full one would cause undue hardship (significant difficulty or cost), and whether an employer may rely on speculative harm to show that hardship. On Feb. 24, 2020, the Supreme Court declined review, so it did not decide those questions and left the Eleventh Circuit's result in place.
Vote
The Court declined review on Feb. 24, 2020. No vote count or opinion lineup is provided here.
Impact
The dispute matters to workers seeking schedule changes or other religious accommodations, such as someone who cannot work on a Sabbath day. It also matters to employers deciding whether they must try a limited accommodation instead of denying the request outright.
What's next
There is no further Supreme Court action in this docket. The lower-court result stays in place, but the broader legal questions may return in another case.
What was the main fight in Patterson v. Walgreen Co.?
The petition asked whether Title VII can require a partial religious accommodation when a full one would be too burdensome. It also asked whether an employer can claim hardship based on predicted, not proven, harm.
Who could feel the real-world effects of this dispute?
Employees who need schedule changes for religious practice could be affected, especially workers who cannot work on certain holy days. Employers also could be affected when deciding how far they must go to adjust work rules.
What happened next after the Supreme Court's action?
The Court ended its involvement by declining review. That means the Eleventh Circuit's result remained in place, and the Supreme Court did not answer the merits questions.
Decision
What the Court decided
The Supreme Court did not take up the case, so it did not resolve the Title VII accommodation questions raised in the petition.
Impact
The dispute matters to workers seeking schedule changes or other religious accommodations, such as someone who cannot work on a Sabbath day. It also matters to employers deciding whether they must try a limited accommodation instead of denying the request outright.
Not official Court text.
Opinion documents
Documents
Related cases




Grounding
- Grounding
- Primary materials plus reporting.
- Note
- Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
- Checked
- Jun 1, 2026
- Method
- Methodology
Primary materials8
Supreme Court docket 18-349
docket | Jun 1, 2026
Primary case document
Supreme Court document | Jun 1, 2026
CourtListener docket record
docket | Jun 1, 2026
Opinion
opinion | Feb 24, 2020
Petition
brief | Sep 14, 2018
Lower Court Orders/Opinions
order | Jul 11, 2018
SupremeCourt.gov
official | Jun 1, 2026
SupremeCourt.gov
official | Jun 1, 2026