This educational guide is based on the linked primary sources. It is not a Court publication, is not affiliated with the Court, and is not legal advice.
In brief
Overview
The Supreme Court granted certiorari for Gerald Groff v. Louis DeJoy.
According to Petitioner Gerald Groff, Gerald Groff sued under Title VII of the Civil Rights Act of 1964, asserting that the United States Postal Service could accommodate his Sunday Sabbath practice without undue hardship.
The Court held that Title VII imposes no requirement that the employer accommodate the plaintiff’s religious practice.
The Court held that requiring an employer to bear more than a de minimis cost to give an employee Saturdays off constitutes an undue hardship.
The judgment of the Court of Appeals was vacated and the case was remanded for further proceedings consistent with this opinion.
According to Justice Alito, justice Marshall (dissent) suggested that the collective‑bargaining agreement might have disallowed Hardison’s working overtime for regular wages.
- [1] 948200fc87ca5ae2b9d4-r1-6b17b9d84575b1bb.pdf, p. 2
- [2] 948200fc87ca5ae2b9d4-r1-6b17b9d84575b1bb.pdf, p. 2
- [3] 948200fc87ca5ae2b9d4-r1-6b17b9d84575b1bb.pdf, p. 17
- [4] 948200fc87ca5ae2b9d4-r1-6b17b9d84575b1bb.pdf, p. 19
- [5] 948200fc87ca5ae2b9d4-r1-6b17b9d84575b1bb.pdf, p. 28
- [6] 948200fc87ca5ae2b9d4-r1-6b17b9d84575b1bb.pdf, p. 18
Background and question before the Court
According to Petitioner Gerald Groff, the case arose from Gerald Groff’s claim that the United States Postal Service could accommodate his Sunday Sabbath practice without undue hardship under Title VII.
What each side argues
Petitioner – Gerald Groff
According to Petitioner Groff, Groff prefers the phrase “significant difficulty or expense” rather than “de minimis” to describe the level of hardship required for an employer to deny accommodation.
Respondent – United States Postal Service (represented by Solicitor General Prelogar)
According to General Prelogar, the “de minimis” language should not be taken literally to immunize employers from liability.
Amicus – Trans World Airlines (TWA)
According to TWA, TWA’s brief asserted that the religious accommodation requirement of Title VII violates the Establishment Clause of the First Amendment.
What happened at oral argument
Justice Thomas asked whether the law being considered in Hardison was Title VII as amended or a guideline.
Justice Sotomayor questioned whether the Court was being asked to overrule not just the de minimis test but the entire holdings of Hardison.
Justice Alito asked about the relevance of a requested accommodation that conflicts with a collective‑bargaining agreement.
Justice Gorsuch asked whether paying a premium wage for Saturday or Sunday work would be enough to excuse an employer from the undue‑hardship test.
According to Chief Justice Roberts, Chief Justice Roberts thanked counsel and noted that the case was submitted.
What the Court decided
The Court held that Title VII imposes no requirement that the employer accommodate the plaintiff’s religious practice.
The Court held that requiring an employer to bear more than a de minimis cost to give an employee Saturdays off is an undue hardship.
The judgment of the Court of Appeals was vacated and the case was remanded for further proceedings consistent with this opinion.
According to Justice Alito, justice Marshall (dissent) suggested that the collective‑bargaining agreement might have disallowed Hardison’s working overtime for regular wages.
Why it matters
Terms to know
No glossary terms are available for this guide.
Primary sources
Read the source materials on the official site or open the immutable repository copy used for this guide.
- 948200fc87ca5ae2b9d4-r1-6b17b9d84575b1bb.pdfopinion
- cabffa77978c551b65ce-r1-724b7b0fea5d8684.pdforal argument transcript
Guide generated September 29, 2026. Automated validation accepted this version.