Third Circuit: Religious Accommodations Must Entirely Resolve Conflict with Work Requirements


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May 25, 2022


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In Groff v. DeJoy, the Third Circuit Court of Appeals stated that religious accommodations under Title VII of the Civil Rights Act of 1964 must eliminate the conflict between an employee’s religious beliefs and work requirements. There, a U.S. Postal Service employee requested to be exempt from Sunday work to observe the Sabbath. Although the employee was allowed to swap shifts with co-workers, he was disciplined when he was unable to obtain coverage and did not show up for work.


The circuit court stated that merely allowing the employee to swap schedules with co-workers was not a statutory accommodation because it did not entirely eliminate the work conflict with the employee’s religious beliefs. Despite this interpretation, the employer demonstrated that the entire elimination of the conflict constituted an undue hardship.

Action Items

  1. Review religious accommodation procedures with legal counsel for compliance.
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