In Groff v. DeJoy, (3d Cir., May 25, 2022), the U.S. 3rd Circuit Court of Appeals, in a 2-1 decision, held that accommodating a Sunday sabbath observer by allowing him not to report for work on Sunday would cause an "undue hardship" to the U.S. Postal Service. Thus, failure to grant that accommodation did not violate Title VII of the 1964 Civil Rights Act. In reaching that conclusion, the court agreed with those circuits that interpret "reasonable accommodation" under Title VII to mean an accommodation that totally eliminates the conflict between job requirements and religious practice. Judge Hardiman, dissenting, said that USPS had not satisfied its burden at the summary judgment stage to prove undue hardship, though it might be able to do so with more facts at trial. Courthouse News Service reports on the decision. [Thanks to Scott Mange for the lead.]
