Groff v. Dejoy

600 U.S. 447 (2023)

Facts

P is an Evangelical Christian who believes for religious reasons that Sunday should be devoted to worship and rest, not “secular labor” and the “transport[ation]” of worldly “goods.” P is employed with the United States Postal Service (USPS), which has more than 600,000 employees. He became a Rural Carrier Associate, a job that required him to assist regular carriers in the delivery of mail. This work generally did not involve Sunday work. In 2013, USPS entered into an agreement with Amazon to begin facilitating Sunday deliveries, and in 2016, USPS signed a memorandum of understanding with the relevant union (the National Rural Letter Carriers’ Association) that set out how Sunday and holiday parcel delivery would be handled. The order in which USPS employees are to be called on for Sunday work outside the peak season is as follows. First in line are each hub’s “Assistant Rural Carriers”- part-time employees who are assigned to the hub and cover only Sundays and holidays. Second are any volunteers from the geographic area, who are assigned on a rotating basis. And third are all other carriers, who are compelled to do the work on a rotating basis. P fell into this third category, and after the memorandum of understanding was adopted, he was told that he would be required to work on Sunday. He then sought and received a transfer to Holtwood, a small rural USPS station that had only seven employees and that, at the time, did not make Sunday deliveries. But in March 2017, Amazon deliveries began there as well. USPS made arrangements. During the peak season, Sunday deliveries that would have otherwise been performed by P were carried out by the rest of the staff, including the postmaster, whose job ordinarily does not involve delivering mail. During other months, P’s Sunday assignments were redistributed to other carriers assigned to the regional hub. P received “progressive discipline” for failing to work on Sundays. Finally, in January 2019, he resigned. P sued under Title VII, asserting that USPS could have accommodated his Sunday Sabbath practice “without undue hardship on the conduct of [USPS’s] business.” The District Court granted summary judgment to USPS and the Third Circuit affirmed. P appealed.