In the rolling hills of Lancaster County, Pennsylvania, where Amish buggies still share the road with modern vehicles and centuries-old traditions persist alongside contemporary life, Gerald Groff found himself at the center of a legal battle that would quietly reshape the landscape of religious freedom in American workplaces. What began as a simple request to observe his Christian Sabbath on Sundays evolved into a unanimous Supreme Court decision that has fundamentally altered the balance of power between employers and employees of faith across the nation.
The story of Groff’s journey through the federal court system represents more than a single individual’s struggle to maintain his religious convictions while earning a living. It embodies a broader transformation in how America’s highest court views the intersection of faith and work—a shift that promises to reverberate through corporate boardrooms, government agencies, and small businesses nationwide for decades to come. The implications of this judicial evolution extend far beyond the quiet post offices of rural Pennsylvania, touching the lives of millions of workers whose religious practices had previously been deemed too burdensome for employers to accommodate.
The Making of a Precedent
Gerald Groff’s story begins in the pastoral landscape of southeastern Pennsylvania, where he worked as a rural carrier associate for the United States Postal Service in the small communities of Quarryville and Holtwood. As an evangelical Christian, Groff held deep convictions about the sanctity of Sunday as a day of worship and rest, beliefs that had guided his life long before they would guide American jurisprudence. For years, these convictions coexisted peacefully with his professional responsibilities, as the Postal Service traditionally observed Sunday as a day of rest for its employees.
The transformation came in 2013, when the Postal Service entered into a contractual agreement with Amazon.com to deliver packages on Sundays as part of an effort to remain competitive and financially viable in an increasingly digital world. This seemingly mundane business decision would set in motion a series of events that would ultimately reach the highest court in the land. For Groff, the new Sunday delivery requirement created an irreconcilable conflict between his professional obligations and his deeply held religious beliefs.
Initially, the Postal Service attempted to accommodate Groff’s religious needs through various arrangements. They assigned other carriers to cover his Sunday shifts, sometimes requiring postmasters themselves to take on delivery duties, and redistributed workloads among other employees at the regional hub. However, these arrangements proved increasingly difficult to sustain due to chronic shortages of rural carriers—a challenge that many postal facilities across the country continue to face today.
As the accommodation efforts repeatedly failed and Sunday coverage became more problematic, the Postal Service began progressive disciplinary action against Groff for his refusal to work on Sundays. The conflict escalated through warnings and formal disciplinary measures, ultimately leading to Groff’s resignation from his position. Rather than accepting this outcome as inevitable, Groff chose to challenge the decision in federal court, arguing that the Postal Service could have accommodated his religious beliefs without imposing an undue hardship on its operations.
The Legal Landscape Before Groff
To understand the revolutionary nature of the Supreme Court’s decision in Groff v. DeJoy, it is essential to examine the legal framework that had governed religious accommodations in the workplace for nearly half a century. The foundation of this framework was established in the 1977 case Trans World Airlines v. Hardison, where the Supreme Court ruled that requiring an employer “to bear more than a de minimis cost” to provide a religious accommodation “is an undue hardship.”
The Hardison decision created what legal scholars and practitioners came to know as the “de minimis” standard—a test that allowed employers to deny religious accommodation requests if they imposed anything more than minimal cost or inconvenience. Over the decades following Hardison, this standard was interpreted by lower courts in ways that “effectively nullified” the promise of Title VII’s religious accommodation protections, as Justice Marshall had predicted in his dissenting opinion in the original case.
The practical effect of the de minimis standard was profound and far-reaching. Religious minorities, who make up less than 1% of the general population, brought more than 18% of all Title VII religious accommodation claims, suggesting that the existing legal framework was failing to protect those who needed it most. There had been an eighty-seven percent increase in the number of religious discrimination charges filed with the Equal Employment Opportunity Commission over the ten years preceding the Groff decision, indicating growing workplace tensions around religious accommodation issues.
The de minimis standard had become so restrictive that courts allowed employers to deny religious accommodation requests that imposed “almost any” additional cost or burden. This created what many religious liberty advocates described as an impossible choice for devout employees: they could either compromise their religious convictions or risk losing their livelihoods. The Muslim Public Affairs Council captured this dilemma in their brief to the Supreme Court, noting that the Hardison standard “forces devout employees to make an impossible daily choice between religious duty and livelihood.”
The Supreme Court’s Unanimous Revolution
On June 29, 2023, the Supreme Court issued a unanimous decision that fundamentally transformed the legal landscape for religious accommodations in the workplace. Writing for the Court, Justice Samuel Alito delivered an opinion that rejected the de minimis cost test that had governed workplace religious accommodation cases for 46 years. The Court held that “showing more than a de minimis cost is no longer sufficient to qualify as undue hardship under Title VII.”
The new standard established by the Court requires employers to demonstrate that granting a religious accommodation “would result in substantial increased costs in relation to the conduct of its particular business.” This represents a dramatic shift from the previous framework, moving from a standard that protected employers from minimal inconvenience to one that requires demonstration of substantial burden.
The unanimity of the decision was particularly significant, suggesting broad consensus across ideological lines that the previous standard had failed to adequately protect religious liberty in the workplace. Justice Alito noted in the opinion that “a bevy of diverse religious organizations has told this Court that the de minimis test has blessed the denial of even minor accommodation in many cases, making it harder for members of minority faiths to enter the job market.”
The Court’s analysis was comprehensive and deliberative, examining not only the statutory language of Title VII but also its legislative history and the practical impact of the Hardison standard over nearly five decades. The Court reasoned that undue hardship “means something very different from a burden that is merely more than de minimis, i.e., something that is ‘very small or trifling.'” This linguistic analysis underscored the Court’s view that the previous standard had strayed far from Congress’s original intent in enacting Title VII’s religious accommodation provisions.
Immediate Impact and Implementation Challenges
The Groff decision has created immediate and far-reaching changes in how employers must approach religious accommodation requests. Employers can now expect to receive more religious accommodation requests, including requests for scheduling changes and time off, and requests for exemptions from vaccine requirements, as employees gain confidence that their requests will be taken more seriously under the new standard.
The Equal Employment Opportunity Commission, which enforces Title VII, has begun updating its guidance to reflect the new standard, though the Court noted that “a good deal of the EEOC’s guidance in this area is sensible and will, in all likelihood, be unaffected by the Court’s clarifying decision.” This suggests that while the fundamental standard has changed, many of the practical approaches to religious accommodation remain valid.
For federal agencies, the impact has been particularly pronounced. On July 16, 2025, the Office of Personnel Management issued a memorandum entitled “Reasonable Accommodations for Religious Purposes” to provide guidance concerning the roles of leave and workforce flexibilities, including telework, as religious accommodations. The guidance encourages agencies to adopt a generous approach to approving religious accommodations while maintaining operational efficiency.
OPM specifically told agencies that telework on a limited basis “is often a low-cost solution” for religious accommodations, since it “typically does not impose substantial operational burdens.” This represents a significant shift in federal employment practices, particularly as the Trump administration has simultaneously sought to reduce telework options for other purposes.
The Broader Scope of Protected Religious Practices
The Groff decision’s impact extends far beyond scheduling accommodations like those sought by Gerald Groff himself. The new standard affects “all sorts of religious accommodations tied to scheduling, dress, and even abortion. That could include the ability for a Muslim woman to wear a hijab or a Christian person to attend Sunday church or an employee’s decision to refuse vaccines on religious grounds.”
The expansive nature of what constitutes religious practice under Title VII ensures that the Groff standard will apply to a wide range of workplace situations. Title VII defines “religion” very broadly, including not only “traditional, organized religions such as Christianity, Judaism, Islam, Hinduism, and Buddhism” but also “religious beliefs that are new, uncommon, not part of a formal church or sect, or only held by a small number of people.”
This broad definition means that employers must now carefully evaluate accommodation requests that might previously have been dismissed as too burdensome under the de minimis standard. Common religious accommodations might include “schedule changes for religious holidays or prayer breaks, permitting religious expression in the workplace, modifications of workplace policies and dress codes, or even job reassignment.”
The decision has been particularly welcomed by religious minority communities who had faced disproportionate challenges in securing workplace accommodations. As Joshua McDaniel, director of Harvard University’s Religious Freedom Clinic, noted, “This decision is especially important for religious minorities, like Muslims, Jews, and Sikhs, who are predominantly the plaintiffs in these cases.” The new standard promises to provide these communities with “a fair shot in court” and encourage employers to adopt more inclusive workplace policies.
Employer Responsibilities and Practical Implications
The Groff decision has fundamentally altered the calculus for employers when evaluating religious accommodation requests. The Court made clear that employers cannot simply analyze whether one accommodation is reasonable; instead, they “must try to find a way to accommodate the employee.” This creates an affirmative obligation for employers to engage in creative problem-solving when faced with religious accommodation requests.
The Court provided specific guidance on what constitutes an inadequate employer response, noting that “if an employer faces a situation similar to the one presented in Groff, it is not enough for the employer to deny the accommodation because it would require other workers to work overtime. Rather, the employer would have to evaluate other options, such as voluntary shift swapping.”
This guidance suggests that employers must now engage in a more comprehensive analysis of accommodation options, considering not just the most obvious solutions but exploring creative alternatives that might minimize burden while still respecting the employee’s religious needs. The Court also clarified that “a coworker’s dislike of a certain religious expression is not enough for undue hardship, nor are impacts on coworkers unless there are corresponding effects on the ‘conduct of the business.'”
For many employers, this will require significant changes to their human resources practices and policies. Every employer should now “develop and implement a clear policy on how employees can make accommodation requests and how those requests are evaluated. This policy should be included in any employee handbook and made widely available to employees.”
The new standard also requires more sophisticated documentation and analysis when employers believe they must deny accommodation requests. Employers who deny religious accommodations must now demonstrate that granting the accommodation “would result in substantial increased costs in relation to the conduct of its particular business,” a burden that is significantly higher than the previous de minimis standard.
The Interactive Process and Good Faith Requirements
One of the most significant practical changes resulting from the Groff decision is the enhanced emphasis on the interactive process between employers and employees seeking religious accommodations. If an employee requests religious accommodation, “the employer must engage in an interactive process to determine other possible options if the requested accommodation would result in an undue hardship.”
This interactive process requirement means that employers cannot simply reject accommodation requests out of hand, even if the specific accommodation requested might pose challenges. Instead, they must work collaboratively with employees to explore alternative solutions that might meet the employee’s religious needs while minimizing business impact.
The good faith nature of this process is crucial. If the employer denies the requested religious accommodation, “it has the burden of showing undue hardship,” and this burden must be supported by concrete evidence rather than speculative concerns about potential problems.
The Court’s emphasis on considering “all relevant factors” means that the analysis must be comprehensive and context-specific. Courts must now “take into account all relevant factors in the case at hand, including the particular accommodations at issue and their practical impact in light of the nature, size, and operating cost of an employer.” This suggests that what constitutes an undue hardship for a small business might be quite different from what constitutes an undue hardship for a large corporation.
Sector-Specific Implications
The impact of the Groff decision varies significantly across different employment sectors, with some industries facing more substantial adjustments than others. In the federal government sector, the changes have been particularly pronounced, as evidenced by the comprehensive guidance issued by the Office of Personnel Management.
Federal agencies are now encouraged to adopt “a generous approach to approving religious accommodations, prioritizing employee needs while maintaining operational efficiency.” This represents a significant cultural shift in federal employment practices, particularly in agencies that have traditionally operated under rigid scheduling and attendance requirements.
The healthcare sector faces unique challenges in implementing the new standard, particularly around vaccination requirements and certain medical procedures. Healthcare employers must now carefully balance patient safety considerations with employees’ religious accommodation requests, often requiring creative solutions such as reassignment to different units or alternative duties.
Educational institutions, particularly public schools and universities, must navigate the intersection of religious accommodation rights with their obligations to maintain secular environments. The Groff standard may make it more difficult for these institutions to deny accommodation requests for religious expression or observance, even when such accommodations might be controversial within the educational community.
Private sector employers in industries with traditionally rigid scheduling requirements—such as manufacturing, retail, and hospitality—face particular challenges in adapting to the new standard. These industries often operate on tight margins and standardized processes, making religious accommodations potentially more disruptive and costly.
Economic and Business Considerations
The economic implications of the Groff decision are complex and multifaceted, with potential benefits and costs for both employers and employees. From an employer perspective, the new standard creates additional compliance obligations and potential liability, as religious accommodation requests that might previously have been dismissed as too costly must now be seriously evaluated.
However, the decision may also create business benefits for employers who embrace inclusive accommodation practices. Companies that develop reputations for respecting employees’ religious needs may find themselves better able to attract and retain diverse talent, particularly as the American workforce becomes increasingly religiously diverse.
John Meiser, director of the Religious Liberty Clinic at Notre Dame Law School, characterized the decision as “a long overdue correction to an error that has eroded the protections that Congress enacted to safeguard workers’ rights from destruction by their employers,” noting that “for decades, courts have permitted even the richest or most powerful employers to deny religious needs that would have cost next to nothing to allow.”
The decision may also reduce litigation costs for employers in the long term, as the clearer standard provides better guidance for decision-making and may reduce the number of accommodation disputes that escalate to formal legal proceedings. When employers are required to engage in more thorough accommodation analyses, they may discover creative solutions that satisfy both business needs and religious requirements.
For employees, the decision represents a significant expansion of workplace rights, but it also creates new responsibilities. Employees seeking religious accommodations must still demonstrate that their beliefs are sincerely held and be willing to engage in good faith in the interactive process with their employers.
Challenges and Criticisms
Despite the broad support for the Groff decision across religious and political lines, the ruling has not been without its critics and challenges. Some employment law experts have expressed concern that the new standard may create practical difficulties for employers, particularly small businesses that operate with limited resources and staffing flexibility.
The concern is particularly acute in industries where religious accommodations might require significant operational changes or create safety risks. For example, accommodating religious dress requirements in manufacturing environments with strict safety protocols, or scheduling accommodations in emergency services where coverage is critical, may pose genuine challenges that courts will need to address as the new standard is implemented.
Labor unions have also expressed mixed reactions to the decision. While many support expanded religious accommodation rights in principle, they are concerned about potential impacts on collectively bargained work rules and seniority systems. The Court noted that undue hardship may still be shown “if the request for an accommodation violates the terms of a collective bargaining agreement or job rights established through a seniority system,” but the practical application of this principle in specific cases remains to be seen.
Some critics have also raised concerns about potential abuse of the expanded accommodation rights, worrying that employees might claim religious motivations for preferences that are actually based on convenience or personal choice rather than sincere religious belief. However, the requirement that religious beliefs be “sincerely held” provides some protection against such abuse, and courts have developed substantial experience in evaluating the sincerity of religious claims.
The Role of Technology and Modern Work Arrangements
The Groff decision comes at a time when technological advances and changing work arrangements are creating new possibilities for religious accommodations that might not have been available when the original Hardison standard was established. Remote work, flexible scheduling, and digital communication tools have made it easier for employers to accommodate religious practices without significant business disruption.
The Office of Personnel Management’s guidance specifically highlighted telework as “often a low-cost solution” for religious accommodations, recognizing that modern technology can enable creative accommodation solutions. An employee who needs time off for religious observances might be able to work remotely during traditional business hours, or use flexible scheduling to make up time while still fulfilling their religious obligations.
Digital platforms also enable new forms of religious expression and observance that require workplace accommodation. Employees might need access to prayer applications on workplace devices, breaks for online religious services, or accommodations for virtual religious observances. The Groff standard requires employers to seriously consider these modern forms of religious practice when evaluating accommodation requests.
However, technology also creates new challenges. The increasing prevalence of surveillance and monitoring in modern workplaces might conflict with certain religious practices, and employers must balance productivity concerns with accommodation obligations. The rise of artificial intelligence and automated scheduling systems may also need to be modified to account for religious accommodation requirements.
International and Comparative Perspectives
The Groff decision has attracted attention beyond American borders, as other countries grapple with similar questions about balancing religious freedom with workplace efficiency. The European Union’s approach to religious accommodation in employment, while different in specific details, faces many of the same fundamental tensions between individual rights and business needs.
Canada’s approach to religious accommodation, which requires employers to accommodate religious practices to the point of “undue hardship,” provides an interesting comparison to the American system both before and after Groff. Canadian courts have generally interpreted undue hardship more generously than American courts did under the de minimis standard, suggesting that the Groff decision may bring American practice closer to international norms.
The decision also has implications for multinational employers who must navigate different religious accommodation requirements across jurisdictions. Companies with operations in multiple countries may find it administratively simpler to adopt accommodation practices that meet the highest standards required in any jurisdiction, potentially leading to a global expansion of religious accommodation practices.
Looking Forward: Implementation and Future Developments
As the legal community continues to digest the implications of the Groff decision, several key areas of development are likely to emerge in the coming years. Courts will need to provide more specific guidance on what constitutes “substantial increased costs” in various business contexts, and employers will need to develop new practices and policies to comply with the enhanced accommodation requirements.
The Equal Employment Opportunity Commission is expected to issue updated guidance that provides more specific direction on how to implement the new standard. This guidance will likely include examples of accommodations that do and do not meet the substantial increased cost threshold, helping employers make more informed decisions about accommodation requests.
Training and education will be crucial for successful implementation of the new standard. Managers, human resources professionals, and others involved in making accommodation decisions will need to be trained on how to respond to religious accommodation requests under the new framework. This training will need to address not only the legal requirements but also best practices for engaging in the interactive process and exploring creative accommodation solutions.
The business community is likely to develop new resources and tools to help employers navigate religious accommodation requirements. Professional organizations, consulting firms, and legal practitioners are already beginning to offer specialized guidance on implementing the Groff standard effectively.
The Continuing Legacy of Gerald Groff’s Stand
While the Supreme Court’s decision represents a legal victory for religious accommodation rights, it is worth noting that Gerald Groff himself “may not ultimately win” his specific case, as the Court remanded the matter to lower courts for reconsideration under the new standard. The local postmaster sometimes had to deliver mail himself and his coworkers had to take on more weekend shifts to accommodate Groff, and these burdens might still constitute substantial increased costs under the new framework.
However, Groff’s personal outcome is less significant than the broader legal transformation his case has created. The decision has already begun to affect thousands of workplace accommodation disputes across the country, providing enhanced protections for employees whose religious practices conflict with work requirements.
The case also represents a broader trend toward greater protection of religious liberty in American law. The Supreme Court’s unanimous support for strengthening religious accommodation rights reflects a growing recognition that previous legal frameworks had inadequately protected the religious freedom that is fundamental to American values.
A Transformed Workplace Landscape
The Groff v. DeJoy decision represents more than a technical adjustment to employment law—it embodies a fundamental shift in how American society balances individual religious freedom with business efficiency. By rejecting the de minimis standard that had governed workplace religious accommodations for nearly half a century, the Supreme Court has signaled its commitment to ensuring that Americans do not have to choose between their faith and their livelihood.
The practical implications of this decision will continue to unfold over the coming years as employers, employees, and courts work to implement the new standard in countless workplace situations. The interactive process requirements, the enhanced burden on employers to demonstrate undue hardship, and the emphasis on creative accommodation solutions all point toward a more collaborative and inclusive approach to workplace religious diversity.
For Gerald Groff, the postal worker whose simple request to observe his Sabbath sparked this legal revolution, the decision represents vindication of his belief that American workplaces should have room for religious conviction. His willingness to challenge an accommodation denial that many would have quietly accepted has created new opportunities for millions of American workers to maintain their religious practices while contributing to the nation’s economic life.
The quiet transformation that began in the hills of Lancaster County has rippled across the entire American workplace landscape, creating new protections for religious liberty that will endure long after the specific circumstances of Groff’s case are forgotten. In a nation founded on principles of religious freedom, the Supreme Court’s unanimous decision in Groff v. DeJoy represents a reaffirmation of those founding values and their continued relevance in modern American life.
As employers and employees navigate this new legal landscape, the spirit of accommodation and mutual respect that underlies the Groff decision offers a path forward that honors both religious conviction and business necessity. The challenge now lies in implementation—transforming legal principle into workplace practice in ways that respect the dignity and beliefs of all Americans while maintaining the economic vitality that provides opportunities for all workers, regardless of their faith traditions.
The revolution may have been quiet, but its effects promise to be both profound and enduring, touching the lives of countless Americans who seek to integrate their deepest beliefs with their daily work. In recognizing that substantial increased costs, rather than minimal inconvenience, should be the standard for denying religious accommodations, the Supreme Court has helped ensure that the American workplace remains a place where people of all faiths can flourish while contributing their talents to the common good.
Adrian Hawthorne is a celebrated author and dedicated archivist who finds inspiration in the hidden stories of the past. Educated at Oxford, he now works at the National Archives, where preserving history fuels his evocative writing. Balancing archival precision with creative storytelling, Adrian founded the Hawthorne Institute of Literary Arts to mentor emerging writers and honor the timeless art of narrative.