Yesterday, the U.S. 3rd Circuit Court of Appeals heard oral arguments (audio of full arguments) in Groff v. DeJoy. In the case, a Pennsylvania federal district court (full text of district court opinion) dismissed Title VII claims brought by an Evangelical Christian postal worker who resigned after receiving warning letters and suspensions for refusing to work on Sundays. The district court rejected claims of religious discrimination and held that plaintiff had been offered shift swapping that met the "reasonable accommodation" requirement of Title VII. The Third Circuit has not previously decided an issue on which the Circuits are split-- whether an employer must wholly eliminate a conflict between work and religion in order for an accommodation to be reasonable under Title VII. The district court concluded that complete elimination is not required.
