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United States Court of Appeals for the Third Circuit
January 25, 2022, Argued; May 25, 2022, Filed
[*164] OPINION OF THE COURT
SHWARTZ, Circuit Judge.
Plaintiff Gerald Groff is a Sunday Sabbath observer whose religious beliefs dictate that Sunday is meant for worship and rest. As a result, Groff informed his employer, the United States Postal Service ("USPS"), that he was unable to work on Sundays. USPS offered to find employees to swap shifts with him, but on more than twenty Sundays, no co-worker would [**2] swap, and Groff did not work. Groff was disciplined and ultimately left USPS.
Groff sued USPS1 for violating Title VII by failing to reasonably accommodate his religion. Because the shift swaps USPS offered to Groff did not eliminate the conflict between his religious practice and his work obligations, USPS did not provide Groff a reasonable accommodation. The accommodation Groff sought (exemption from Sunday work), however, would cause an undue hardship on USPS, and so we will affirm the District Court's order [*165] granting summary judgment in USPS's favor.
USPS employs several types of postal carriers. One type is a Rural Carrier Associate ("RCA"). An RCA is a non-career employee who provides coverage for absent career employees. RCAs work "as needed," so the job requires flexibility. JA456. RCAs do not accrue leave, and any leave they take is unpaid. USPS also employs Assistant Rural Carriers ("ARCs") who are hired to work only on Sundays and holidays. At the time of Groff's employment, there was a shortage of RCAs in his region.
Groff joined USPS in 2012. He became an RCA that year. In March 2014, Groff transferred to the Quarryville Post Office, where he worked until he transferred to [**3] the Holtwood Post Office in August 2016. Groff remained at Holtwood until he resigned from USPS in January 2019.
In 2013, USPS contracted with Amazon to deliver Amazon packages, including on Sundays. Amazon delivery initially began at only some post offices and the scheduling of RCAs was left to each postmaster's discretion.2 The success of Amazon Sunday delivery was critical to USPS.
Full case includes Shepard's, Headnotes, Legal Analytics from Lex Machina, and more.
35 F.4th 162 *; 2022 U.S. App. LEXIS 14195 **
GERALD E. GROFF, Appellant v. LOUIS DEJOY, Postmaster General United States Postal Service
Subsequent History: US Supreme Court certiorari granted by Groff v. Dejoy, 2023 U.S. LEXIS 403 (U.S., Jan. 13, 2023)
Prior History: [**1] Appeal from United States District Court for the Eastern District of Pennsylvania. (D.C. No. 5-19-cv-01879). U.S. District Judge: Honorable Jeffrey L. Schmehl.
Groff v. Dejoy, 2021 U.S. Dist. LEXIS 66174, 2021 WL 1264030 (E.D. Pa., Apr. 6, 2021)
accommodation, undue hardship, scheduled, Postmaster, employees, reasonable accommodation, coworkers, religious, religious practice, carriers, hub, exempting, holiday, shifts, swap, observer, overtime, season, post office, delivery, religious belief, district court, costs, summary judgment, disciplined, assigned, coverage, religion, religious discrimination, job requirement
Labor & Employment Law, Religious Discrimination, Scope & Definitions, Covered Employees & Employers, Religion Defined, Burdens of Proof, Employee Burdens, Defenses, Reasonable Accommodation & Undue Hardship, Discriminatory Employment Practices, Discharges, Discipline & Transfers, Burden Shifting, Business & Corporate Compliance, Labor & Employment Law, Discrimination, Accommodation, Disability Discrimination, Reasonable Accommodations, Undue Hardship, Failures to Hire, Wage & Hour Laws, Overtime & Work Periods