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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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.