No. 19-1388October Term 2019Decided Apr 5, 2021Updated Apr 5, 2021
Small v. Memphis Gas, Light & Water
This case asks whether an employer unlawfully denied Jason Small a religious accommodation under Title VII when it refused his request related to his religious observance.
Case status
Decided · April 5, 2021
Read the opinion (PDF)- Current stage
- Decided
- Latest event
- Decision released Apr 5, 2021
- What it's about
This case asks whether an employer unlawfully denied Jason Small a religious accommodation under Title VII when it refused his request related to his religious observance. More broadly, the petition asks the Supreme Court to reconsider the rule that an employer faces an "undue hardship" whenever an accommodation would impose more than a minimal cost.
Question presented
Whether this Court should revisit and perhaps overrule its statement in Trans World Airlines, Inc. v. Hardison, 432 U.S. 63, 84 (1977), that requiring an employer “to bear more than a de minimis cost” to accommodate an employee’s religious practice “is an undue hardship” for purposes of Section 701(j) of the Civil Rights Act of 1964, Title VII, 78 Stat. 255, Pub. L. 88-352, as added by the Equal Employment Opportunity Act of 1972, 86 Stat. 103, Pub. L. 92-261, codified at 42 U.S.C. § 2000e-2(j).
- Case path
United States Court of Appeals for the Sixth Circuit / Decision released Apr 5, 2021
- Area
Civil Rights
Timing
Decided April 5, 2021
The Court released its decision on April 5, 2021 without hearing oral argument.
Documents
Activity
Docket activity2
Opinion added: Opinion
Apr 5, 2021 | Court records
Brief added: Petition
Jun 15, 2020 | Court records
Related cases
Grounding
- Grounding
- Primary-source trail available.
- Note
- Plain-English explainer. Official filings and opinions remain authoritative.
- Checked
- Jul 25, 2026
- Method
- Methodology