On June 29, 2023, the U.S. Supreme Court in Groff v. DeJoy clarified the "undue hardship" standard under which an employer may deny a religious accommodation under Title VII of the Civil Rights Act of 1964. In a unanimous opinion authored by Justice Samuel Alito, the court rejected a "de minimis cost" test and held that an employer denying a religious accommodation must show that the burden of granting an accommodation "would result in substantial increased costs in relation to the conduct of its particular business."