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Rh that obligated employers “to make reasonable accommodations to the religious needs of employees” whenever that would not work an “undue hardship on the conduct of the employer’s business.” 29 CFR § 1605.1 (1968).

Between 1968 and 1972, the EEOC elaborated on its understanding of “undue hardship” in a “long line of decisions” addressing a variety of policies. Hardison, 432 U. S., at 85 (Marshall, J., dissenting); see Brief for General Conference of Seventh-day Adventists as Amicus Curiae 10–22 (collecting decisions). Those decisions addressed many accommodation issues that still arise frequently today, including the wearing of religious garb and time off from work to attend to religious obligations.

EEOC decisions did not settle the question of undue hardship. In 1970, the Sixth Circuit held (in a Sabbath case) that Title VII as then written did not require an employer