A recent decision by the U.S. Circuit Court of Appeals for the Third District, provides a bit more clarity as to an employer’s obligations to make a reasonable accommodation for an employee’s religious observations and beliefs. In the matter of Groff v DeJoy, Groff had advised his employer the US Postal Service that his religious beliefs prohibited him from working on Sundays. He was able to avoid Sundays on his schedule until USPS contracted with Amazon to deliver packages seven days each week. Groff proposed they accommodate his religious beliefs by not requiring him to work on Sundays. In response, the USPS made numerous attempts to avoid the conflict by having other employees cover Groff’s shifts and even offering him late arrival after he attended religious services. None of these “accommodations” worked and after progressive disciplining, Groff resigned and filed suit claiming a violation of Title VII of the Civil Rights Act which prohibits employment discrimination on the basis of race, color, religion, sex and national origin. Judge Jeffrey Schmehl of the US District Court for the district of Pennsylvania granted summary judgement to the USPS and dismissed the lawsuit. Groff then appealed the decision and, the appellate court made clear on the one hand that reasonable attempts to accommodate such as those made by the USPS did not meet the definition of reasonable accommodation as they did not remove or resolve the conflict. On the flip side however, the court ultimately affirmed the lower court decision and granted summary judgement to the USPS since the reasonable accommodation sought by Groff would have created an undue hardship on the Postal Service. Consequently, the USPS had not violated Title VII by not accepting his proposed accommodation.