Christian USPS Worker Ends Case That Set Undue Hardship Test (2)

The US Postal Service and a Christian letter carrier whose lawsuit about working Sundays spurred a landmark US Supreme Court ruling have resolved the case, federal court records show.

Gerald Groff and the USPS told the US District Court for the Eastern District of Pennsylvania that the 2019 lawsuit “has been settled,” the clerk of the court said Monday in a docket entry. The case “is dismissed with prejudice, pursuant to agreement of counsel,” the order said.

Terms of the settlement weren’t included in the court record or shared by counsel for the parties.

Groff alleged that after exempting him from Sunday work for years the agency declined to further accommodate his religious observance, forcing him to quit. The USPS said continuing to give Groff Sundays off would have posed an undue hardship on its operations, including imposing extra overtime costs, harming efficiency, increasing worker safety hazards, and decreasing employee morale.

The case went to the Supreme Court, which in 2023 ruled that to avoid Title VII of the 1964 Civil Rights Act liability under an undue-hardship defense, employers must show a religious accommodation “would result in substantial increased costs in relation to the conduct of its particular business.” The ruling clarified that showing a de minimis harm isn’t enough, rejecting a test that had widely been used by lower courts.

“We are thankful the Supreme Court ruled in our favor 9-0, overturning decades of bad law trampling religious liberty in the workplace,” Hiram Sasser, an attorney for Groff, said Tuesday. “We appreciate the Department of Justice’s efforts to bring this case to a final and fair resolution, as well as the diligent work and partnership of Baker Botts, Church State Council, and Independence Law Center. Our client, Mr. Groff, is delighted with the outcome of his case,” he said. Sasser is executive general counsel at First Liberty Institute.

The office of the US Attorney for the Eastern District of Pennsylvania declined to comment on the accord, except to say that the parties are still working through the written agreement and that it would be made available once finalized.

The high court’s clarification of the undue hardship standard is being applied by district and circuit courts nationwide in a variety of contexts, including requests not to use transgender names and pronouns, the denial of religious exemption requests from employer Covid-19 vaccine mandates, and the need to tolerate an employee’s anti-abortion messaging.

The settlement between Groff and the USPS obviates the need for a trial in the case, which had been scheduled to begin on Aug. 19. Judge Jeffrey L. Schmehl had ruled Jan. 30 that a jury needed to weigh the parties’ competing undue-hardship evidence under the clarified standard set by the justices.

Baker Botts LLP, Cornerstone Law Firm LLC, Church State Council, and Independence Law Center also represented Groff. The Justice Department represented the USPS.

The case is Groff v. DeJoy, E.D. Pa., No. 5:19-cv-01879, case dismissed 5/5/25.