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Religious Accommodations: US Supreme Court Heightens Undue Hardship Standard

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By Michael Burkhardt, A. Klair Fitzpatrick, Thomas Linthorst, David Salmons, Daniel Kadish, Tova Katims
| Lexology Verified
The US Supreme Court issued a unanimous decision on June 29, 2023 in Groff v. DeJoy, revising the standard for undue hardship in the context of religious discrimination claims brought under Title VII. The Court held that an employer demonstrating a hardship that is merely “more than de minimis”—the previously accepted standard for undue hardship since 1977—is not sufficient.
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