Appeals court vacates earlier decision upholding school district’s pronoun policy, sends back to trial court in light of Supreme Court’s recent Title VII ruling

The Court clarified that the standard an employer must meet for establishing an “undue hardship” is not the “de minimis cost” test used by courts for many years – including by the 7th Circuit in Kluge – but is instead whether a religious accommodation would “result in substantial increased costs in relation to the conduct of its particular business.”