USPS can require Christian postal carrier to work on Sundays, appeals court rules
A federal appeals court panel has ruled against a U.S. Postal Service employee who sought religious exemptions from working on Sundays because of his faith.
A three-judge panel for the U.S. 3rd Circuit Court of Appeals ruled against Pennsylvania postal worker Gerald Groff in a decision released Wednesday.
Groff, a former employee of the Quarryville Post Office in Lancaster County who opposed working on Sundays, argued that he could only avoid working on Sundays by switching shifts with other employees.
Circuit Judge Patty Shwartz, an Obama appointee, wrote that if Groff were to receive exemptions from working on Sundays, the accommodations "would cause an undue hardship" for the postal service.
"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 reads.
Although USPS doesn't typically deliver mail on Sundays, it will occasionally do so under "certain circumstances," such as priority mail or delivering Amazon packages.
As a rural carrier associate, Groff had never been asked to work Sundays until the U.S. Postal Service expanded about four years after he started the job. The expansion involved employees working Sundays for Amazon package delivery in rural areas.
Following the expansion, Groff was not in attendance for dozens of his work shifts that fell on Sundays. The only option Groff felt he had was to swap shifts with another employee.
The USPS brass told Groff that due to the shortage of staff, it is bound by a collective bargaining agreement that mandated that a Sunday rotation be part of rural carrier associates' job requirements.
For missing multiple shifts, Groff received disciplinary action. In response, Groff resigned from his job and filed his lawsuit under Title VII of the Civil Rights Act.
In April 2021, U.S. District Judge Jeffrey L. Schmehl, an Obama appointee, dismissed Groff's case because the plaintiff failed to show that he was "treated differently with regards to Sundays because he was a Christian."
Clinton appointee and Circuit Judge Julio Fuentes joined the Shwartz opinion. Circuit Judge Thomas Hardiman, a George W. Bush appointee, authored a partial dissent in which he wrote that "a conflict had to be totally eliminated to result in reasonable accommodation under Title VII."
"Inconvenience to Groff's coworkers alone doesn't constitute undue hardship. 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."
Baker Botts attorney Christopher Tutunjian, who represented Groff, said in a statement that he was "pleased with the Third Circuit's unanimous holding that a 'reasonable accommodation' under Title VII must completely eliminate the work-religion conflict."
"This holding correctly addresses a circuit-splitting issue and will protect the religious rights of employees throughout the Circuit," stated Tutunjian, as reported by Courthouse News Service.
"However, as Judge Hardiman persuasively explained in his partial dissent, the majority's erroneous conclusion that USPS established undue hardship only underscores the need for the Supreme Court to address the continued vitality of the Court's decision in TWA v. Hardison. We are considering our options for further review."