Justices Rule in Favor of Evangelical Christian Postal Worker

(FamilyConservationPAC.com) – Federal law prohibits employers from mistreating employees because of their religious beliefs unless the employer can demonstrate that the employee’s religious beliefs cannot be “reasonably” accommodated without “undue hardship.”

The Supreme Court ruled that a trivial burden is not the kind of “undue hardship” that will justify an employer’s failure to accommodate an employee’s religious beliefs.

“The company must instead provide accommodations for an employee’s religious beliefs unless it can demonstrate that doing so would “result in substantially increased costs in relation to the conduct of” the employer’s business,” the court noted.

Justice Samuel Alito penned an opinion piece for the court. Justice Ketanji Brown Jackson and Justice Sonia Sotomayor contributed to a concurring opinion.

The ruling was largely a victory for the plaintiff in the case, Gerald Groff.

 Groff, an evangelical Christian who believes that Sundays should be reserved for rest and worship. Still, he was fired in 2019 after being penalized for refusing to go to work on Sundays.

Trans World Airlines v. Hardison, a 1977 ruling on the definition of the “undue hardship” clause, had been recommended to be overturned by Groff.

Instead, Groff said that the judges should rule that businesses must respect their workers’ religious beliefs unless doing so would be extremely difficult and expensive.

The justices declined to change their earlier decision or adopt that high criterion. Still, they did remand Groff’s case to the lower court for further consideration following the criteria they laid forth on Thursday.

The phrase “undue hardship” has been used by lower courts since Hardison to include “any effort or cost that is “greater than… de minimis,”” but Alito argued that this view is “a mistake” in a 21-page judgment.

According to Alito, the court’s ruling in Hardison primarily addressed whether federal employment discrimination laws forced the airline and the union to respect a worker’s religious beliefs at the expense of their seniority rights.

According to Alito, the issue of when additional expenses qualify as an “undue hardship” hasn’t gotten much attention.

In light of this, Alito argued that although the court’s opinion in Hardison stated that it would be an “undue hardship” to require the airline to “bear more than a de minimis cost in order to give Hardison Saturdays off” to observe the Sabbath, that language was not necessarily intended as an “authoritative interpretation” of what it means to be an “undue hardship.”

Alito pointed out that, in contrast, the court stated “three times that an accommodation is not required when it entails’ substantial’ costs’ or ‘expenditures'” in another place in the Hardison case.

According to Alito, a stricter criterion is also more in line with the meaning of “undue hardship.” The phrase “hardship,” according to Alito, “is more severe than a mere burden.”

“A burden must be “extreme” or “unjustifiable” to be considered “undue,” according to Alito, which is “quite different from a burden that is only more than de minimis, i.e., something that is “very minor or insignificant.”

Both the Biden administration’s proposal, which focused on the “substantial expenditures” or “substantial additional costs” that the employer would incur, and Groff’s suggestion that the employer must accommodate the employee’s religious practices, were rejected by Alito.

Instead, Alito said, “It is enough to say that an employer must show that the burden of granting an accommodation would result in substantially increased costs in relation to the conduct of its particular business.”

Alito next remanded Groff’s case to lower courts for additional proceedings. He wrote that the U.S. Court of Appeals for the 3rd Circuit may have overlooked alternative accommodations because it had relied on the “more than de minimis cost” standard and not taken into account “the cost of incentive pay, or the administrative costs of coordination with other nearby stations with a broader set of employees.”

He suggested that the lower courts should use “the clarified context-specific standard” that the court had laid down on Thursday.

While Groff had asked the justices to rule that the employer must demonstrate “undue hardship to its business” by accommodating an employee’s religious practices, Sotomayor and Jackson wrote separately to point out that the court on Thursday had indicated only that the employer must demonstrate “undue hardship on the conduct of the employer’s business” – which, Sotomayor emphasized, could include burdens on the business’s employees.

Indeed, Sotomayor emphasized, “for many businesses, labor is more important than any other factor to the conduct of the business.”

The First Liberty Institute, which represented Groff, praised the judgment in a press release as being “far-reaching” and ensuring that “fewer religious employees will have to choose between their faith and their job.”

According to the organization, Thursday’s decision “means that more employers will be legally required to respect their religious employees by granting them accommodations,” which religious employees “often seek” “to honor their holy days, to take prayer breaks during the day, to dress according to their religious beliefs, or to otherwise not be forced to violate their religious beliefs on the job.”

A group that frequently opposes First Liberty, the Baptist Joint Committee for Religious Liberty, also applauded Thursday’s ruling.

Holly Hollman, the chief counsel for the BJC, referred to the decision as a “victory for religious minorities, who disproportionately claim the need for workplace accommodations.”

According to Hollman, the unanimous decision made today “points us in a positive direction where all Americans across ideological and religious differences can come together to defend faith freedom for all,” even if “there will undoubtedly be future disputes.”

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