A federal appeals panel ruled against a Christian and former Pennsylvania mail carrier who sought a religious exemption from the U.S. Postal Service (USPS) to avoid working Sundays.
Gerald Groff, who worked at post offices in Lancaster County, Pennsylvania, argued that his civil rights under Title VII were violated because he could only avoid working on Sundays by switching shifts.
The three-judge panel for the U.S. 3rd Circuit Court of Appeals disagreed.
USPS does not usually deliver mail on Sundays, but will occasionally make exceptions, such as for priority mail or Amazon packages.
Groff was working for USPS as a rural carrier associate (RCA) for about four years and had not been asked to work a Sunday shift until USPS contracted with Amazon to deliver packages to rural areas, including on Sundays.
The USPS brass told Groff that because of short staffing and a collective bargaining agreement mandating Sunday rotation for RCAs, his only way to avoid working on Sundays would be to switch shifts with a coworker every time he was asked to work.
Groff missed dozens of shifts that fell on a Sunday, for which he was progressively disciplined. He ultimately resigned and filed a lawsuit under Title VII of the Civil Rights Act.
Circuit Judge Patty Shwartz, who was appointed by former President Barack Obama, argued that allowing Groff not to work on Sundays "would cause an undue hardship" for the USPS.
"Exempting Groff from working on Sundays caused more than a de minimis cost on USPS because it actually imposed on his coworkers, disrupted the workplace and workflow, and diminished employee morale," the ruling read.
Shwartz was joined by Circuit Judge Julio Fuentes, a Clinton appointee.
Circuit Judge Thomas Hardiman, an appointee of former President George W. Bush, issued a partial dissent that said "a conflict had to be totally eliminated to result in reasonable accommodation under Title VII."
Hardiman also questioned to what extent Groff’s scheduling requests would burden the USPS.
"Inconvenience to Groff’s coworkers alone doesn’t constitute undue hardship," Hardiman argued.
"Neither snow nor rain nor heat nor gloom of night stayed Gerald Groff from the completion of his appointed rounds," Hardiman wrote. "But his sincerely held religious belief precluded him from working on Sundays. Because USPS has not yet shown that it could not accommodate Groff’s Sabbatarian religious practice without its business suffering undue hardship, I respectfully dissent."