According to court filings, Gerald Groff was a rural carrier who requested Sundays off for religious reasons after the Postal Service agreed to deliver packages for Amazon, including on Sundays.

The local postmaster attempted to accommodate Groff, but he was still scheduled for some Sunday shifts and faced disciplinary action when he failed to report for them.

The postmaster told Groff it was difficult to cover his shifts and that the extra work affected employee morale and the post office's ability to complete deliveries.

Groff resigned in 2019 and sued the Postal Service in the U.S. District Court for the Eastern District of Pennsylvania, alleging the agency failed to reasonably accommodate his religious practices in violation of Title VII.

The District Court granted summary judgment to the Postal Service and the 3rd Circuit affirmed, concluding that it would impose more than a de minimis cost, and thus an undue hardship, on the agency to exempt Groff from working on Sundays.

Read more: 2022 LBEDBRF 0054.

Groff appealed to the Supreme Court, saying the court should reconsider Hardison's "de minimis" standard, suggesting it goes against Congress' intent in 1972 amendments to Title VII that require a reasonable accommodation for employees' religious practices barring undue hardship.

"This court gutted those vital protections in dicta utterly divorced from the statutory text, declaring that employers could deny religious accommodations that impose 'more than a de minimis cost,'" the petition for certiorari said.

The government agreed that the standard was incorrect, pointing to Hardison's references to "substantial expenditures" and "substantial additional costs."

Courts have misinterpreted Hardison, the high court said, noting that while subsequent rulings have focused on that decision's use of the "de minimis" phrase, the opinion repeatedly uses the terms "substantial," "costs" and "expenditures."

"We therefore, like the parties, understand Hardison to mean that 'undue hardship' is shown when a burden is substantial in the overall context of an employer's business," the court said.

But, it cautioned, courts must apply the standard based on "all relevant factors" in each case.

The high court declined to grant either party's requests in clarifying the standard, saying they "go too far." Groff had suggested it tell courts to follow Americans with Disabilities Act case law based on its "significant difficulty or expense" standard for accommodations, while the solicitor general sought an affirmation of the Equal Employment Opportunity Commission's understanding of Hardison.

"What is most important is that 'undue hardship' in Title VII means what it says, and courts should resolve whether a hardship would be substantial in the context of an employer's business in the common-sense manner that it would use in applying any such test," the court said.

An employer cannot cite impact on other employees as "undue hardship" based on employee animosity toward a religion, the court noted.

"If bias or hostility to a religious practice or a religious accommodation provided a defense to a reasonable accommodation claim, Title VII would be at war with itself," Justice Alito wrote.

Aaron M. Streett of Baker Botts LLP represented Groff. U.S. Solicitor General Elizabeth B. Prelogar represented the Postal Service.