Employers Win Most Accommodation Claims Before Trial
Operators handling religious accommodation requests face a tougher post-Groff litigation landscape, according to Cornell research.
Updated on Nov. 3, 2026 in Employment
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Employers won 76% of religious accommodation claims dismissed before trial in 46 rulings following the Supreme Court's unanimous 2023 decision in Groff v. DeJoy, according to a Cornell University study. That rate compares with a 51% employer summary judgment win rate across 49 decisions from roughly two decades before the ruling, for businesses handling workplace accommodation requests.
Why it matters
The Groff decision made it harder for employers to reject religious accommodation requests, so the study's figures suggest that a higher share of these claims are being resolved before trial than before the ruling. For operators, that shift bears on how much legal exposure an accommodation dispute carries and how carefully requests must be documented.
Employers obtained pre-trial dismissal of failure-to-accommodate claims in 76% of 46 post-Groff rulings, compared with a 51% employer summary judgment win rate across 49 pre-Groff decisions from about two decades earlier. The figures come from a Cornell University analysis of federal rulings on religious accommodation claims.
The players
Cornell University
A private research university whose researchers analyzed post-Groff federal rulings on religious accommodation claims.
Bloomberg Law
A legal news and analytics service that reported on the Cornell study's findings on employer win rates.
The details
Under Groff v. DeJoy, the Supreme Court unanimously held in 2023 that employers face a higher bar when rejecting religious accommodation requests. The Cornell study compared 46 rulings issued after the decision with 49 summary judgment decisions from the two decades before it. The comparison measures how often employers prevailed before trial in each period, which is the stage where many of these claims are resolved.
Timeline
2023: The Supreme Court unanimously decided Groff v. DeJoy.
November 3, 2026: Bloomberg Law reported the Cornell study's findings on employer win rates.
Market Landscape
The Supreme Court's unanimous 2023 decision in Groff v. DeJoy tightened the standard employers must meet when rejecting religious accommodation requests. The Cornell study tracks how federal courts have resolved these claims since that ruling, offering a benchmark against the summary judgment patterns that predated it.
Operators should review how accommodation requests are documented and evaluated, since the post-Groff figures suggest employers are winning fewer disputes on the merits at trial. Human resources and legal teams should consult qualified employment counsel on how the Groff standard applies to their own policies.
The takeaway
The Cornell figures show employers prevailing more often before trial on accommodation claims since Groff, which makes documentation of each accommodation decision more important. Operators should route specific accommodation policy questions to qualified employment counsel.
Further reading
For more on how workplace rules and employer obligations are shaping hiring and labor practices, see the Employment section.
Source note: This article includes information reported by Bloomberglaw.
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