Redefine Title VII undue hardship as significant difficulty or expense

Research notes

• pre_satisfied under ADR 0003: the ask is conditional and its condition was met before 2025-01-20. Groff is at https://www.supremecourt.gov/opinions/22pdf/22-174_k536.pdf — outside the evidence window, so it is recorded here rather than as frontmatter Evidence.
• Groff’s formulation (“substantial increased costs in relation to the conduct of its particular business”) is not word-for-word the ADA’s “significant difficulty or expense” that the Quote asks Congress to import. A reviewer could therefore read the ask as still open, which would put it at a plain not started without the flag. Flagged for the consistency pass.
• Confirmed 2026-09-01 (ticket 26 phase 2, pre_satisfied batch), flag kept. An expand ask addressed to Congress, not a preserve or continue ask, so the flag is available. The Quote makes its own condition explicit — Congress should act “unless the Supreme Court overrules its bad precedent” — and the Court did, before the window. On the Quote’s own terms nothing remains outstanding, which is the “nothing outstanding” test met on the ask’s wording rather than on the reviewer’s preferred wording. The word-for-word objection above is noted and not acted on: it would have the site hold an ask open that its own text closes.
• One in-window instrument moves in the same direction on a different object: DOL’s announced direct final rule RIN 1291-AA52 would “amend the undue burden standard applicable to religious accommodations” in 29 CFR 38.6(f), the WIOA nondiscrimination regulation — not Title VII. It had not published by 2026-08-31.
• Checked 2026-09-06 (read-queue ticket 06, Already-true sweep): flag stands. What satisfied this ask is a Supreme Court holding, Groff v. DeJoy (2023), and the object would be undone by the Court overruling Groff or by Congress legislating the de minimis standard back. Neither has happened, and no bill of the 119th Congress amends the Title VII undue-hardship standard. DOL’s RIN 1291-AA52 moves the same way on a different regulation (29 CFR 38.6(f), WIOA) and had not published. Nothing inside the window undoes the object.