Groff v. DeJoy
In brief
An employer cannot deny a religious workplace accommodation based only on a minor cost or inconvenience.
- Where it stands
- Decided
Decided 9-0 · June 29, 2023 · Opinion by Justice Alito
- What it’s about
- A former postal worker sued the U.S. Postal Service under Title VII of the Civil Rights Act after being disciplined for refusing to work on Sundays due to his religious beliefs.
- Who it affects
- Employers must more carefully assess requests such as a religious worker seeking not to work Sundays.
Summary: written with AI from the case record.
What it's about
The Supreme Court clarified the standard for when an employer can deny a religious accommodation, ruling that employers must show that granting the request would result in substantial increased costs rather than just a trivial burden.
The decision strengthens the standard employers must meet before denying religious accommodations in the workplace.
Question presented
Is inconvenience to coworkers an “undue burden” under Title VII of the Civil Rights Act of 1964 such that it excuses an employer from providing an accommodation requested for religious exercise?
What the Court decided
Holding
Title VII requires an employer that denies a religious accommodation to show that the burden of granting an accommodation would re - sult in substantial increased costs in relation to the conduct of its particular business. 35 F. 4th 162, vacated and remanded.
- Result
- Vacated
The vote
- Joined the judgment
- Concurred in a separate opinion
- Wrote an opinion
- Majority · 8joined the Court's opinion
- Concurring · 1agreed with the result, wrote separately
- Sotomayorwrote separately
From the opinions
“An employer must show that an accommodation would result in “substantial increased costs in relation to the conduct of its particular business.””
What's next
Lower courts will apply the Court’s substantial-cost standard as this case returns for further proceedings. Employers and agencies will need to evaluate religious accommodation requests under that stricter test.
Why it matters
Coworker inconvenience alone does not meet the required standard unless the accommodation would substantially increase costs for the employer’s particular business.
Documents
Docket activity
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
AI analysis generated: Decision Record
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AI analysis generated: Case Briefing
Opinion added: Groff
Opinion added: opinion
Brief added: Petition
Brief added: Questions Presented
More questions
- What did the Supreme Court rule in Groff v. DeJoy?
- The Court said employers must show substantial increased costs to deny a religious accommodation under Title VII. A minor burden is not enough.
- Who is affected by the Groff v. DeJoy decision?
- Workers seeking religious schedule changes and their employers are affected. For example, a worker requesting Sundays off may receive stronger protection.
- What happens next in Groff v. DeJoy?
- The case returns to the lower courts for further proceedings under the new standard. Other courts must also apply that standard in similar disputes.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.