There were morale problems, the USPS added, and even scheduled Sunday carriers had to deliver more mail than they would if Groff worked on that day.
Groff resigned in January of 2019. He said he left because he did not find an “accommodating employment atmosphere with the USPS that would honor [his] personal religious beliefs.”
Suit Alleges Title VII violations
He eventually sued, alleging disparate treatment and denial of accommodation under Title VII.
A lower court granted summary judgment against him. It said the USPS showed that entirely exempting Groff from working on Sundays would cause it undue hardship. In so doing, it noted that granting Groff’s request would require every other RCA to work every Sunday.
On appeal, the Third Circuit explained that “a legally sufficient accommodation under Title VII’s religious discrimination provision is one that eliminates the conflict between the religious practice and the job requirement.”
That did not happen here, the appeals court said.
Although the USPS allowed Groff to swap shifts, the accommodation was not a reasonable one under the statute because other employees were not regularly available to cover Groff’s Sunday shifts. In other words, the suggested accommodation was not effective.
It was not enough, the appeals court said, that the offered accommodation could theoretically have solved the problem.
Shift-swapping can be a reasonable way to accommodate a religious practice, the court added, but here it was not because the needed swaps did not materialize.
Undue hardship shown
The appeals court also decided that the USPS showed that granting Groff’s requested accommodation
would cause it undue hardship.
The requested accommodation imposed on Groff’s co-workers and disrupted the workplace, the appeals court said.
It hurt employee morale and placed a great strain on Groff’s station, it added.
Groff’s absences caused an undue hardship, the court said, and exempting him from Sunday work would cause an undue hardship as well.
The lower court’s ruling was affirmed.
Information provided by HR Morning