Employment Litigation · Primary-source case analysis

Groff v. DeJoy: Religious-Accommodation Undue Hardship Requires Substantial Cost

By Aneeta Mishra and Timothy Chan

Published April 23, 2026

Groff resets the practical inquiry for evaluating an employer’s claimed hardship from accommodating an employee’s religious practice.

A postal worker sought Sundays off

Gerald Groff observed a Sunday Sabbath. After Sunday package delivery expanded, USPS redistributed his assignments, imposed progressive discipline, and he eventually resigned before suing under Title VII.

De minimis cost was not the statutory test

The Court rejected lower-court shorthand derived from Hardison. An employer must show that the proposed accommodation would impose substantial increased costs in relation to the conduct of its particular business.

Coworker effects matter through business impact

Effects on coworkers are relevant when they affect the conduct of the business, but coworker dislike of a religious practice or of accommodation itself cannot establish undue hardship. The employer must assess reasonable alternatives rather than stop at the employee’s preferred proposal.

Disposition

The Court vacated and remanded for application of the clarified standard. It did not decide whether USPS could ultimately establish undue hardship on the developed facts.

Key takeaways

• Document the requested accommodation and alternatives considered.
• Measure operational cost in the context of the actual business.
• Separate coworker animus from legitimate operational impact.
• Use the clarified substantial-cost standard in accommodation decisions.