The case involved a former rural carrier associate who cited his Christian beliefs in refusing to work on Sundays. Image: Phil Pasquini/Shutterstock.com
By: FEDweek StaffThe U.S. Supreme Court has said that a federal agency—along with other employers subject to the Civil Rights Act—must show that they would experience “substantial increased costs in relation to the conduct of its particular business” to justify denying employees’ requests to accommodate their religious views and practices in workplace matters such as shift scheduling.
Groff v. DeJoy involved the law’s requirement that employers make “reasonable accommodations” unless doing so would cause an “undue hardship” to the employer. At issue was the interpretation of a prior Supreme Court ruling saying that the employer must show that making an accommodation would have only more than a “de minimis” [minimal] impact, a standard the new decision said courts have since used to “deny even minor accommodations.”
Its new ruling says that the prior case “cannot be reduced to that one phrase.” That decision “referred repeatedly to ‘substantial’ burdens . . . in the overall context of an employer’s business . . . Understood in this way, ‘undue hardship’ means something very different from a burden that is merely more than de minimis,” the unanimous decision says.
“What an employer must show is that the burden of granting an accommodation would result in substantial increased costs in relation to the conduct of its particular business,” it says. “Courts must apply the test to take into account all relevant factors in the case at hand, including the particular accommodations at issue and their practical impact in light of the nature, size, and operating cost of an employer.”
The case involved a former rural carrier associate—a non-career employee who provides coverage for career employees—who cited his Christian beliefs in refusing to work on Sundays. That became an issue when the USPS began Sunday delivery of packages. While work-arounds were found initially, during peak delivery season it triggered complaints from other employees that they were being assigned to work on Sundays excessively.
Facing potential firing, the employee resigned and filed the suit. A district court and then an appeals court held for the USPS, though, ruling that accommodating him had put more than a minimal burden on the USPS due to the impact on other employees.
The high court’s new ruling says that impacts on coworkers can be considered, but they “are relevant only to the extent those impacts go on to affect the conduct of the business. A court must analyze whether that further logical step is shown. Further, a hardship that is attributable to employee animosity to a particular religion, to religion in general, or to the very notion of accommodating religious practice, cannot be considered ‘undue.’ Bias or hostility to a religious practice or accommodation cannot supply a defense.”
It adds that the Civil Rights Act “requires that an employer ‘reasonably accommodate’ an employee’s practice of religion, not merely that it assess the reasonableness of a particular possible accommodation or accommodations. Faced with an accommodation request like Groff’s, an employer must do more that conclude that forcing other employees to work overtime would constitute an undue hardship. Consideration of other options would also be necessary.”
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