Carter v. Southwest Airlines

The Fifth Circuit adopted a post-Groff analytical framework for Title VII religious discrimination claims, establishing three distinct claim categories and raising the evidentiary bar for the undue hardship defense.

ReligiousLiberty.TV
February 26, 2026
0 min read
Cite This Case
Carter v. Southwest Airlines (2025).
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Carter v. Southwest Airlines (2025). https://religiousliberty.tv/case-library/carter-v-southwest-airlines/
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⚠ No official reporter citation found for this case. Citation quality will improve once a reporter citation (e.g. 573 U.S. 682) is added to the case record.

Carter v. Southwest Airlines [2025] — The Fifth Circuit adopted a post-Groff analytical framework for Title VII religious discrimination claims, establishing three distinct claim categories and raising the evidentiary bar for the undue hardship defense. Source: ReligiousLiberty.TV (https://religiousliberty.tv/case-library/carter-v-southwest-airlines/, accessed April 10, 2026).
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⚠ No official reporter citation found for this case. Citation quality will improve once a reporter citation (e.g. 573 U.S. 682) is added to the case record.

Official citation: (2025)  ·  2025
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Year: 2025
Free Exercise Workplace Accommodation
Holding: The Fifth Circuit adopted a post-Groff analytical framework for Title VII religious discrimination claims, establishing three distinct claim categories and raising the evidentiary bar for the undue hardship defense.
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Official Documents

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Coverage on ReligiousLiberty.TV

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Carter v. Southwest Airlines is a Free Exercise case in 2025. The court held that the Fifth Circuit adopted a post-Groff analytical framework for Title VII religious discrimination claims, establishing three distinct claim categories and raising the evidentiary bar for the undue hardship defense.

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