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The Facts and Procedural History Plaintiff Gerald Groff was employed as a rural postal carrier associate (RCA) for USPS. An RCA is a noncareer employee who provides coverage for absent career employees. RCAs work "as needed," so the job requires flexibility. At the time of Groff's employment, there was a shortage of RCAs in his region. Working on Sunday is required for RCAs in part as a result of USPS's contract with Amazon to deliver Amazon's packages including on Sundays. The success of Amazon Sunday delivery was critical to USPS. As part of union negotiations, only two exceptions were recognized for Sunday work: an individual (1) who had approved leave adjacent to a Sunday or holiday, or (2) whose workweek would exceed forty hours if assigned to work on the Sunday or holiday. Groff describes himself as an evangelical Christian who believes Sundays are meant for worship and rest. His position, however, required him to work on Sundays. Initially, to avoid Amazon Sunday deliveries, Groff obtained a transfer to a small station; however, eventually his small station also began Amazon Sunday deliveries. At that time, Groff requested that he be exempted from working on Sundays as an accommodation for his religious beliefs. Groff's postmaster offered to adjust Groff's schedule to permit Groff to attend religious services in the morning and report to work afterward which was an accommodation offered to others. Eventually, USPS informed Groff that he could be excused from working on Sundays only if another worker was able to cover his shifts. Consequently, the shift swapping created resentment towards management from employees who had to work more Sundays than they should have. Additionally, finding coverage for Groff increased the workload of postmasters (supervisors) in the area who were themselves forced to deliver mail when no RCAs were available since putting off delivery until Monday would have impacted efficiency and safety. Ultimately, despite USPS's efforts to find employees to switch shifts with Groff, USPS could not find available workers for 24 Sundays over 60 weeks. Due to the lack of coverage and Groff not working on those Sundays, he was disciplined, which led to his decision to resign from USPS. The Decision The author thanks law clerk Naomi Gulama for her assistance in drafting this client alert. Choose the preferred chip denomination and click the bet box until the desired amount is wagered. The chip stack starts at $1,000. The game will offer a $1,000 reload if the chip balance drops to $0. The object of blackjack is to get closer to 21 than the dealer without going over. The Wizard of Vegas blackjack game offers advice based on the cards dealt to the player and the dealer's door card, while taking the available rules into consideration. A basic strategy error will cause a pop up window to appear that will suggest a better move, even if the advice option is not clicked before making a decision. WASHINGTON-Fraudulent online reviews, which deceive consumers and damage companies' reputations, are a significant problem. While the public and private sector have taken some steps to address the proliferation of fake reviews, a new report from the Center for Data Innovation concludes that state and federal governments should strengthen their enforcement actions, partner with the private sector to develop best practices, and pass legislation to protect consumers from lawsuits when they leave honest reviews. "The importance of online reviews has opened a new market for fake reviews that present a dishonest impression of companies, goods, and services," said Morgan Stevens, a research assistant with the Center for Data Innovation, who authored the new report. "Companies may turn to employees or bad actors to fraudulently leave positive reviews to boost the image of their products, or negative reviews to discredit those of a competitor. These actions both hurt honest businesses and mislead consumers as to the quality of relevant goods and services." Previous research has found that the negative impact of fake reviews has grown over the years, likely influencing billions of dollars in consumer spending. The Center's new report breaks down the types of fake reviews that proliferate as well as other sources of misrepresentation that impact the online marketplace, including the suppression of negative reviews, lawsuits over negative reviews, the harassment of customers, and payments to silence critics. The FTC should work with review websites, e-commerce sites, and consumer brands to develop best practices for preventing and detecting fake reviews. The FTC should work with the private sector to create best practices for social media companies to identify and remove fake reviews. Read the report.

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