A Shift From the 1977 Standard
For nearly 50 years, businesses relied on a 1977 Supreme Court ruling in Trans World Airlines v. Hardison, which allowed employers to reject religious accommodations if they created “more than a de minimis cost” for the business.
The justices, in a rare 9-0 unanimous decision, agreed with Groff and determined that this standard was far too low. They clarified that employers must provide accommodations unless doing so would cause “substantial increased costs” or an undue hardship, aligning the interpretation more closely with other federal laws, such as the Americans with Disabilities Act (ADA).
Justice Samuel Alito, writing for the Court, emphasized that the Civil Rights Act of 1964 requires a fair balance between respecting religious practice and maintaining workplace efficiency. “The law does not permit trivial burdens on religious exercise to be used as an excuse for denying accommodations