For decades, courts evaluating religious‑accommodation requests under Title VII of the Civil Rights Act of 1964 used the “more‑than‑de minimis cost” test from Hardison. Under that standard, an employer could deny a request if the accommodation imposed even minimal inconvenience or cost — “de minimis” meaning small or trivial.  In practice, this meant that minor scheduling conflicts, modest shift rearrangements, or slight coworker disruptions often were sufficient grounds for denial. As critics long argued, this low threshold effectively rendered religious accommodations optional and fragile, allowing employers to treat religious practice as a burden rather than a protected right.

That changed on June 29, 2023, when the Court unanimously ruled in Groff v. DeJoy that the de minimis standard was a misinterpretation of Title VII. Instead, the Court clarified, employers wishing to deny a religious‑accommodation request must demonstrate that granting it would impose a “substantial increased cost” relative to the business. The Court emphasized that “hardship” must mean something more serious than a mere small burden — “something hard to bear,” “excessive,” or “unjustifiable”— not something trifling.

Under this new standard, employers must look at the full context — including their size, resources, operating costs, and the nature of the requested accommodation — before denying. The decision also clarified that discomfort, animosity, or dislike from coworkers toward the religious observance cannot by itself justify denial. What matters is whether the burden truly affects the employer’s business operations — not whether other employees are unhappy or inconvenienced.

This ruling does not mean that employers must grant every accommodation request. Rather, it recalibrates the balance in favor of religious freedom: accommodation requests now deserve serious, good‑faith consideration, not automatic dismissal based on minor inconvenience. Courts are expected to conduct “fact‑specific inquiries” on a case‑by‑case basis. Employers may still deny on valid grounds — but only when they can show a substantial hardship. Prior reflexive denials based on de minimis conflicts should no longer suffice.

Supporters of the decision have hailed it as a much‑needed reaffirmation that religious liberty in the workplace is not merely theoretical — that personal faith and employment should not be pitted against each other lightly. For employees who observe weekly Sabbaths, religious holidays, prayer times, or other practices, the ruling promises more predictable, fairer treatment. It also encourages employers to engage more creatively — by exploring shift swaps, schedule adjustments, or other accommodations — instead of defaulting to denial.

At the same time, the decision introduces a new dynamic into employment law and workplace management. Because the Court did not adopt a rigid definition of “substantial hardship,” lower courts will now be called on to interpret what counts — creating a period of uncertainty as case law develops. Employers may need to update policies, train supervisors, and document accommodation‑decision processes carefully. On the other side, employees may feel more confident requesting accommodations, but may still face pushback where businesses argue legitimate hardship. How workplaces adjust will depend heavily on context, industry, and willingness to engage in good‑faith accommodations.