Groff v. DeJoy
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Groff v. DeJoy and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Groff v. DeJoy.
Gerald Groff, an Evangelical Christian, sued the United States Postal Service under Title VII for not accommodating his religious practice of observing the Sunday Sabbath. The Supreme Court clarified the standard for 'undue hardship' in religious accommodation cases, emphasizing substantial costs rather than a 'de minimis' standard. The case was vacated and remanded for further proceedings consistent with this clarified standard.
Holding
The single most important “bottom line” of what the Court decided in Groff v. DeJoy.
The Court held that Title VII requires an employer to show that granting a religious accommodation would result in substantial increased costs in relation to its business.
Constitutional Concepts
These are the Constitution-related themes that appear in Groff v. DeJoy. Click a concept to see other cases that involve the same idea.
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Why Free Exercise of Religion is relevant to Groff v. DeJoy
The case centers on the requirement for employers to accommodate religious practices under Title VII, which relates to the Free Exercise Clause.
Syllabus excerpt (verbatim)Groff sued under Title VII of the Civil Rights Act of 1964, asserting that USPS could have accommodated his Sunday Sabbath practice 'without undue hardship on the conduct of [USPS's] business.'
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Why Establishment of Religion is relevant to Groff v. DeJoy
The case discusses potential Establishment Clause concerns in accommodating religious practices, although it is not the primary focus.
Syllabus excerpt (verbatim)At the time, some thought that the Court's now-abrogated decision in Lemon v. Kurtzman... posed a serious problem for the 1972 amendment of Title VII.
Key Quotes
Short excerpts from the syllabus in Groff v. DeJoy that support the summary and concepts above.
Title VII requires an employer that denies a religious accommodation to show that the burden of granting an accommodation would result in substantial increased costs.
Hardison referred repeatedly to 'substantial' burdens, and that formulation better explains the decision.
The Court understands Hardison to mean that 'undue hardship' is shown when a burden is substantial in the overall context of an employer's business.
