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Third Circuit Finds Undue Hardship for USPS in Religious Accommodation Suit

Gerald Groff worked as a postal carrier for the United States Postal Service (USPS). As a postal carrier, the USPS required him to work "as needed." Beginning in 2013, the USPS entered into a contract with Amazon to deliver packages every day of the week. Initially, the Postmaster for Groff's post office exempted him from Sunday work because Groff is a Sabbath observer "whose religious beliefs dictates that Sunday is meant for worship and rest.” However, once it became clear the Postmaster needed him to work Sundays, Groff transferred to another office. When that office began to deliver on Sundays, Groff said he would not be able to work. The Postmaster offered him the option of attending church services and then coming to work. The Postmaster also asked other employees to cover the Sunday morning shift, which became a burden on the few employees in the office. The USPS initiated progressive discipline for Groff after he missed his scheduled Sundays. The USPS offered him the option of observing his Sabbath on another day, which he declined. Groff's continuing absences placed a heavy work burden on the rest of the office and impacted office morale. He resigned.

Groff sued USPS for religious discrimination in violation of Title VII. In reviewing Groff's claims, the Third Circuit Court of Appeals assessed whether the USPS had offered Groff a reasonable accommodation. The court considered an accommodation reasonable if it "eliminates the conflict between employment requirements and religious practices." The court concluded the USPS's proposed accommodation was not reasonable because it did not eliminate the religious conflict. USPS scheduled Groff for 24 Sundays and could not find other employees to swap shifts with him. As a result, Groff missed work, and USPS disciplined him. However, Groff's proposed accommodation that he receive a Sunday exemption would cause an undue hardship to USPS. The appellate court found exempting him from working Sundays caused more than a “de minimis cost" because of its impact on coworkers and disruption to the workplace. For that reason, USPS did not violate Title VII by refusing to grant Groff's accommodation.