Circuit Court Clarifies Employer Burdens in Religious Accommodation Cases

The facts in Groff v. DeJoy were simple and quite typical of work scheduling accommodation cases. Gerald Groff is a Sunday Sabbath observer whose religious beliefs dictate that Sunday is meant for worship and rest. As a result, he notified his employer, the United States Postal Service, that he was unable to work on Sundays. For several years, Mr. Groff was able to avoid working on Sundays by a job transfer, but as a result of a contract under which the Postal Service agreed to deliver Amazon packages every day of the week, an inevitable conflict arose between the demands of the workplace and Mr. Groff’s faith.

The postmaster offered to adjust Mr. Groff’s schedule to permit him to attend religious services on Sunday morning and report to work later in the day, which was an accommodation provided to other employees. Later, the postmaster sought out others to cover Mr. Groff’s shifts, which was the only accommodation he could find that did not adversely impact operations. When there were not enough substitutes available, the postmaster proposed as an alternative that Mr. Groff pick another day of the week to observe his Sabbath, an alternative Mr. Groff rejected.


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