The Supreme Court of the United States (SCOTUS) recently convened to make some of the most significant rulings on religious freedom in recent years. The court held unanimously: “Title VII requires an employer that denies a religious accommodation to show that the burden of granting an accommodation would result in substantial increased costs in relation to the conduct of its particular business.”
The First Amendment Protects God-Given Liberties
Writing for the court, Justice Alito explained:
Petitioner Gerald Groff is an Evangelical Christian who believes for religious reasons that Sunday should be devoted to worship and rest. In 2012, Groff took a mail delivery job with the United States Postal Service. Groff’s position generally did not involve Sunday work, but that changed after USPS agreed to begin facilitating Sunday deliveries for Amazon. To avoid the requirement to work Sundays on a rotating basis, Groff transferred to a rural USPS station that did not make Sunday deliveries. After Amazon deliveries began at that station as well, Groff remained unwilling to work Sundays, and USPS redistributed Groff’s Sunday deliveries to other USPS staff. Groff received “progressive discipline” for failing to work on Sundays, and he eventually resigned.
Groff sued under Title VII of the Civil Rights Act of 1964, asserting that USPS could have accommodated his Sunday Sabbath practice “without undue hardship on the conduct of [USPS’s] business.” 42 U. S. C. §2000e(j). The District Court granted summary judgment to USPS. The Third Circuit affirmed based on this Court’s decision in Trans World Airlines, Inc. v. Hardison, 432 U. S. 63, which it construed to mean “that requiring an employer ‘to bear more than a de minimis cost’ to provide a religious accommodation is an undue hardship.” 35 F. 4th 162, 174, n. 18 (quoting 432 U. S., at 84). The Third Circuit found the de minimis cost standard met here, concluding that exempting Groff from Sunday work had “imposed on his coworkers, disrupted the workplace and workflow, and diminished employee morale.” 35 F. 4th, at 175.
With this decision, the court clarified for lower courts how the 1972 Hardison decision should be applied. It might be argued that this decision effectively guts Hardison but that is for the experts to argue. It effectively prioritizes religious freedom, which is protected by the U. S. Constitution, over inconvenience to an employer. In the Groff case, the USPS might be said to have hunted him down, as it were. When he was hired, Sunday labor was not an issue. It was the USPS who decided to try to compete with UPS (and similar competitors) to make Amazon deliveries. Groff resolved his issue by moving to a rural station, but then that station changed its Sunday work practices. Groff made a good-faith effort to do his work as a mail carrier, but the USPS changed the terms of employment. Wonderfully, with this decision, the court holds that constitutionally protected liberties are not negotiable.
The court also held that religious freedom is not merely about attending religious services. They extend beyond Sundays (for Christians), Saturdays (for Jews), and Fridays (for Muslims). It upholds a more robust understanding of religious freedom.
Christians Can Practice American Citizenship
This was a good term for the first-amendment. In 303 Creative v. Elenis et al., the court upheld the principle that Americans cannot be forced to say things contrary to their conscience. This is a basic human right and a core concern for the American founders. Christians especially should appreciate this decision since it one of the demands made of us by both the ancient and modern pagans is to say certain words. In the second and third centuries AD, the pagan Romans demanded that Christians say “Caesar is Lord” (rather than “Christ is Lord” or “Jesus is Lord;” Rom 10:9; 1 Cor 12:3; Phil 2:11) and that we renounce Jesus. They demanded that we make drink or other offerings to seal that profession. They did not demand that we actually believe what they demanded that we say, but they did demand outward conformity. So it is with the pagans of our day. They demand, in effect, that we say “Caesar is Lord” when they demand that we say that males are females or face a hefty fine from the local “civil rights” commission. They demand that we offer up our children to Moloch in public schools by forcing them to sit through whatever abominations they dream up. In 303 Creative, the state literally sought to punish a businesswoman for refusing to say words that the State of Colorado sought to compel her to say in service of clients who apparently never actually existed. This “couple” was never a couple. There was never going to be marriage, and one of the alleged partners in this ostensible marriage is not even homosexual. It was all a farce fabricated for the purpose of using the coercive power of the state to compel Christians to conform to the new pagan orthodoxy.
The 303 Creative and Groff decisions provide evidence that Christians can act to preserve their civil liberties (and those of others). Recently I argued that Christians can and should oppose the radical sexual agenda being imposed upon the country by highly-organized and well-funded groups. I contended that Christians should 1) pray; 2) organize; 3) persuade; 4) legislate, and 5) litigate (POPLL). These cases are evidence that the instruments of relief provided by the Constitution and in American law are sufficient to preserve our liberties. They are also evidence that it is expensive in funds and time to serve one’s neighbors this way. The 303 Creative case began in 2016 and the Groff case began in 2019. Our fellow citizens (and others) have been working hard to hold the State of Colorado and the USPS to the bargain we have all made with each other in the Constitution.
Fred Greco is right to exhort us, “. . .we should not despair of the rule of law in our nation. Too often, Christians act as if the United States is unalterably hostile to Christianity. Groff’s case shows us that the laws of our nation protect our freedom to live out our faith. That there was not one dissenting vote is surely significant.”
American Christians have certain civil liberties. We can and should exercise them as Paul did: graciously, wisely, and timely. He did, finally, after considerable suffering for Christ’s sake, assert his rights as a Roman citizen. So may we.
But We Will Capitalize?
One thing, however, above all, that strikes me about the Groff case is how easily most American Christians have adapted to the new Sunday regime and culture. How many Christians have done as Groff did and insisted on keeping the Sabbath? Perhaps there were other similar cases—not every case makes it to the Supreme Court, and once there the court does not always agree to hear it—but it does not seem that there has been a flood of Sabbath-related cases before the courts since Hardison.
Why is that? The principle reason is Dispensationalism. The prevalence of Dispensationalism in America has vitiated the role of the Ten Commandments in the life of millions of American Christians. The opinion held by tens of millions of American Christians, who have been influenced by Dispensationalism, is that the Ten Commandments (including the fourth commandment) are “not for today.” Thus, many rejoiced when the so-called “blue laws” (many of them to do with Sabbath regulations) were struck down, and they crowded into cafes and restaurants on the Lord’s Day after church. In 1975, I was a young pagan washing dishes and bussing tables on Sundays, picking up after antinomian evangelical Christians. If the Ten Commandments are “not for today,” what do Dispensationalists care about Sabbath observance or being made to work on Sundays?
Presbyterian and Reformed (P&R) Christians, however, bear their share of blame. The Dispensationalists do not confess the Christian Sabbath. Most of them are likely quite ignorant of the historic Christian theology, piety, and practice of the Sunday Sabbath (no, Constantine did not invent the Sunday Sabbath, Jesus did; Mark 16:2). P&R folk, however, have no excuse. Our confession of God’s Word is clear. We affirm the abiding validity of the fourth commandment until Christ returns. In Heidelberg 103 we say:
What does God require in the fourth Commandment?
In the first place, God wills that the ministry of the Gospel and schools be maintained, and that I, especially on the day of rest, diligently attend church, to learn the Word of God, to use the Holy Sacraments, to call publicly upon the Lord, and to give Christian alms. In the second place, that all the days of my life I rest from my evil works, allow the Lord to work in me by His Spirit, and thus begin in this life the everlasting Sabbath.
When the Lord graciously brought me to new life and true faith, virtually all the evangelical churches in our town held services on Sunday morning and Sunday evening. Some, including my Southern Baptist congregation (before I discovered the Reformed confession), held services on Wednesday evenings too. If a Christian were attending services twice on the Lord’s Day, it would be almost impossible for him also to work a secular job on Sunday.
Since the mid-70s, however, as the Sunday laws were removed, so apparently was the commitment to the Lord’s Day for the evangelical and Reformed. Today, it is difficult, if not impossible, to find an evening service on the Lord’s Day where there is not a Reformed Presbyterian (in North America), Orthodox Presbyterian, or United Reformed congregation.
I understand a little about the pressure to work on Sundays. When in the process of becoming Reformed I was offered a part-time job, for which I was well qualified, which asked me to work on Sundays. I accepted the position on the condition that I would not work on the Lord’s Day. Like Groff, I did my best to accommodate my fellow employees. I worked odd hours (once I worked an evening shift, slept at the station that night, and engineered the morning drive show the next day) so as to remove as much of the burden as possible. It was a radio station and they are typically on the air 365 days a year, 24 hours a day. My employer regularly probed me to see whether I was willing to work on Sundays, and I had to refuse more than once. There was always the possibility that I might lose my job. I was young and poor.
Nevertheless, principles matter. Truth matters. Religious freedom matters. In the providence of God, we Christians have been given an open door to exercise our religious liberties. The question is whether we will see this opportunity for what it is, or whether we will squander it at the beach, in the mall, or at the restaurant.
©R. Scott Clark. All Rights Reserved.
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R. Scott Clark
R.Scott Clark is the President of the Heidelberg Reformation Association, the author and editor of, and contributor to several books and the author of many articles. He has taught church history and historical theology since 1997 at Westminster Seminary California. He has also taught at Wheaton College, Reformed Theological Seminary, and Concordia University. He has hosted the Heidelblog since 2007.
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The providers of rest have to work, to provide it, for the benefit of rest to be available to anyone. The military work being done is, like the priestly work the Lord mentioned (Matthew 12:5), innocent.
Larry,
That’s why the Reformed distinguish between “servile” & “necessary” labor on the Sabbath. Doctors, police, military, nurses, EMS, etc provide necessary labor. Shoe salesman, not so much.
Larry, if we’re talking about the ordinary soldier, I agree with you. When a commander tells a soldier to do “X,” apart from the extraordinarily rare exception of an unlawful order, the soldier is to do “X.” End of issue, unless “X” is something like “kill unarmed civilians at My Lai.” The responsibility for the rightness or wrongness of a lawful order belongs to the commander issuing the order.
It is not true in all cases that all military work on the Lord’s Day is legitimate. What is true is that the commander, not the soldier, bears responsibility for deciding whether the work is legitimate. The parallel would be that in a medieval or Reformation era household, the lord of a manor was correctly held accountable before God and civil authority for ordering his servants to do things that violated what were then both religious and civil prohibitions against unnecessary activities on the Lord’s Day. The servants did what they were told; the lord of the manor bore responsibility. Some of the Reformation and post-Reformation writers commented on the importance of ordering households in ways that didn’t cause servants to miss church services or otherwise do unnecessary things on the Lord’s Day, and I suspect if I looked hard enough, I could find similar things in Catholic and Lutheran books of that era about proper Christian management of a household.
That’s why Machen did the right thing when he followed directives to organize games on Sunday during World War I for soldiers as part of rest and recreation (R&R) for troops close to the front lines in France. Yes, I know Machen was a civilian with the YMCA, but what he was doing was under military authority and the same principles apply. Whether recreation on the Lord’s Day was the right or wrong thing to do wasn’t up to Machen. While it’s true that their Reformed convictions caused the Afrikaners during the Boer War to threaten to open fire on British troops on the Lord’s Day if they didn’t stop recreational activities, something like that would be almost unheard of in modern military operations.
Whether Stonewall Jackson did the right thing to initiate combat on the Lord’s Day is more complicated. Unlike Machen, the decision **DID** belong to General Jackson. Furthermore, in his era, when Lord’s Day issues were still widely understood and one of his fellow Confederate generals, Leonidas Polk, was both a West Point graduate and an Episcopal bishop, General Jackson would have been under little if any pressure from his fellow military leaders, or the Confederate political leadership, to initiate combat if he believed it was unnecessary or unwise to do so. His decision would have been respected in ways that a modern conservative Christian in the US Army cannot expect. Look, for example, at the recent controversy greeting what should have been an unremarkable statement by an American general that Judeo-Christian values underlying American culture make it much less likely that the US military would use artificial intelligence in unethical ways, compared to our potential adversaries who work with a very different ethical framework, or none at all.
(Since people Google, I need to add here that I am defending the Lord’s Day observance principles of Stonewall Jackson, not the Confederate cause for which he and General Polk fought and died, and emphatically not supporting slavery. I have a decades-long history of opposition to the Confederacy. I had an ancestor who left the South where he had been involved in anti-slavery activism, moved North not long before the Civil War broke out, enlisted in the Union Army, and very deliberately chose to fight against slavery.)
My point here is that in a world where people on both sides of a military conflict largely share a similar Christian worldview, questions come up that we don’t face today. If America ever was a Christian nation (a debatable but not indefensible point), it no longer is, and has not been one for a long time.
Questions of Lord’s Day observance on a modern battlefield are moot. Questions of Lord’s Day observance in a garrison or training environment are still relevant, but the controlling factor is that soldiers follow orders. In an American military context, the decisions about use of the Lord’s Day as a training day were made decades ago. The key decisions that are problematic were made in the years following World War II as the United States confronted Cold War realities, the need for a standing army very different from what we had prior to the 1940s, and the need to train a Guard and Reserve component that would be capable of rapid mobilization.
The ordinary soldier doesn’t get to pick and choose whether to obey those decisions, which were made long ago and by people who are long since dead. Maybe those decisions should be revisited, but that’s not going to happen apart from a radical change in American culture that leads to changes in our military and our politics.
You’re latest reply to Leonard is quite encouraging for me as a drafted soldier often required to do unnecessary work on the Sabbath.
Sam, the military is one of the “special cases” with which Reformed people have had to deal for centuries on Sabbath observance. Dr. Clark used to serve a congregation close to Camp Pendleton. I live outside Fort Leonard Wood. There are very real issues that Reformed Christians see in military communities that most of the modern civilian world rarely if ever sees.
However, these are far from being new issues. The Swiss Reformed preachers served congregations imbued with a military culture that had existed long before the Reformation, and was unlike almost anything we see in the modern world — the Swiss were known all over Europe for their military skills and were highly sought after as mercenaries (which raises another whole set of problems with which the Reformed also had to deal in the 1500s). It wasn’t just the high mountains of the Swiss Alps. Reformed Christianity, if not born in blood, was certainly fighting for its very survival, not merely with sermons and with words but with swords and cannon and early firearms, for most of its early history and for most places where Reformed Christianity spread all over Europe.
A farmer understands the difference between necessary work on the Lord’s Day and work which is unnecessary, or which can be postponed, or which with proper planning can usually but not always be avoided. Much the same can be said historically of military leaders, including our early Reformed forebears who not uncommonly had been involved in direct military combat as younger men, or who as pastors had to deal with military realities as a matter of simple self-preservation of their cities or countries. Let’s not forget that the main subjects of study at the Huguenot Academy of Sedan, in the then-independent Principality of Sedan in what is now northeastern France, were theology and military science. Early Reformed leaders understood that their ability to preach the Word depended upon the power of the sword to defend the freedom of the pulpit.
Both Jewish and Christian history show clearly that refusing to fight on the Sabbath is a guarantee of utter destruction at the hands of enemy military forces. It’s obvious that when the Japanese attacked Pearl Harbor on Sunday morning, the sailors and other military personnel in Hawaii were right to fight back. Where things get complicated is deciding when military necessity requires doing something on the Lord’s Day, not to respond to direct military attack or to prepare for such an attack or to deter an attack, but in a training environment or non-deployed garrison conditions.
A key issue to remember is that for ordinary soldiers, the responsibility for most military orders lies with the command, not the individual. A decision of whether potentially problematic activities are or are not appropriate on the Lord’s Day is, quite literally, “above my pay grade” for almost all people wearing the uniform. In a modern American military context, even the three- and four-star generals in TRADOC, FORSCOM, etc., are implementing decisions made decades ago by Pentagon-level officials on how the military should handle such matters as weekend training. It is not the responsibility of the ordinary soldier to decide, for example, whether the National Guard needs to be training on Sunday. The decision to move toward normalization of weekend training was controversial at the time, but the decisions were made decades before anyone now in uniform joined the military, and long before any current members of Congress were serving, and it would require, quite literally, an act of Congress to change some of those decisions. (Personally, I think in a Cold War environment there was an obvious need to improve the training of the National Guard and turn it into a functioning military force, and the decision can be defended in a post-World War II context. The only viable alternative would have been a much larger peacetime draft to create de facto universal military training comparable to that of Israel or South Korea. Whether we still have 1950s-era conditions requiring that as a matter of military necessity is a whole different subject, but we are so far away from the “cultural Christian consensus” of 1950s America that most of our political leaders wouldn’t even know how to have those debates.)
We also shouldn’t regard decisions to have military personnel do potentially problematic things on the Lord’s Day as a sign of liberalism or of compromise or of infiltration of broad evangelical views. Reformed Christians known for their fiery commitment to conservative theology with as widely varying political allegiances as Stonewall Jackson and J. Gresham Machen had to confront Lord’s Day issues under military conditions. For General Jackson, it had to do with ordering men into combat on the Lord’s Day. For Machen, who took leave from his Princeton Seminary professorship to serve with the YMCA during World War I (the Army chaplaincy was very different from what it is today, and Machen believed he would have more opportunities for direct contact with troops serving behind the lines with American troops in France in the YMCA than he would have in uniform), he had to deal with directions from his supervisors to help organize sports and other R&R activities for soldiers on Sunday close to and often recently returning from the front lines in France.
General Jackson was in charge of making the decision. Machen was not. And that is a very important distinction to remember — the responsibility before God is borne by the man who gives the order.
Some will point out that American soldiers choose to serve. There are Reformed Christians who argue that Christians should not voluntarily choose to serve in the military because of problems such as Lord’s Day observance. That’s a serious mistake and smacks of Anabaptism, though I realize the Reformed arguments are more complex than those of the Anabaptists against military service. The main reason military service is not required today in the United States is because American policies several generations ago eliminated the threat from multiple enemy nations that wanted to destroy the United States — and if it had not been for conservative Christians who (correctly) regarded the fights against the Nazis, against Imperial Japan, and against the Communists as matters of existential survival for American Christianity, the world would be a very different place today.
While we do have an all-volunteer force today in the United States, that’s not true of some of our allies. South Korea is probably the most relevant example today where there is a very real and very serious need for a strong military force to deter, and if necessary to stop, aggression from a very dangerous hostile power immediately north of the border. A South Korean draftee who refuses military service faces years in a very nasty Korean prison unless he can obtain rarely-granted exemptions for medical or other reasons, and given the threat of North Korea, it seems pretty obvious that most of what South Korea does by way of military training can be defended as a matter of military prudence, if not of absolute military necessity.
We don’t want to get into what is admittedly an extreme example when some of the Boer commanders, during their war with the British in what became South Africa, threatened to open fire on British personnel under siege conditions who were doing recreational activities on the Lord’s Day.
But if I were in South Korea, where there is a considerably higher percentage of Reformed Christians who understand Lord’s Day issues than there is in the United States, I might want to be asking some important questions about how to organize military service in ways that honor the Lord’s Day. We can’t realistically ask those questions in the modern United States — imagine the nonsensical debate in Congress that would happen if a hypothetical Reformed member of Congress tried to have such a debate with Alexandra Ocasio-Cortez or Nancy Pelosi.
There are countries that could and perhaps should be having such debates, but we no longer have the tools to have such debates in America, or the level of widespread Christian consensus to make the debates worthwhile.
@William Duncan. This case was very close to my heart because I’ve done and volunteered to do in my job exactly the things Mr. Groff did in order to preserve Sunday worship and ideally the Sabbath. In crunch times where we’re working weekends, I routinely take on extra hours during the weekdays and holidays as well in addition to loading up Friday and Saturday. Sometimes I still have to work due to externally imposed legal project deadlines (from management or the client) and I grieve that, but especially if someone’s picking up Sunday, I’ll try to work the hours others don’t want to so at minimum I can have morning worship and ideally the day off.
That’s sometimes meant 20-25+ hours of work between Friday and Saturday and I’m happy to do it.
I wonder if Christians who are asking for Sunday off are volunteering to work on Saturday. “Six days thou shalt labor…” Not five.
Reports are that Groff sought to accommodate his employer in a variety of ways. I think Christians who face this crisis are willing to work Saturdays.
You raised a very practical question. Accommodating the religious beliefs of a religious employee often makes good business sense if the employee is well-known for taking his work ethics seriously. On the other hand, employees who are lazy bring discredit upon their religious beliefs if they claim to be religious.
Christians who refuse to work on the Lord’s Day (and also Orthodox Jews and Seventh Day Adventists who refuse to work on the Jewish Sabbath) typically are pretty conservative people who have strong work ethics and therefore have zero problem with working six days a week if it means not working on their day of religious obligation. For employers who are trying to accommodate the religious beliefs of valued employees who they know are not trying to come up with excuses not to work, that usually means an employer appreciates an employee who is willing to work every Friday night and every Saturday, when many people want time off, in return for never working on Sunday. Of course, if an employer hates religion, that employer is going to find ways to get rid of a religious employee regardless of what the law says. Refusing to work on Sunday can become a convenient excuse.
Newspapers are 24-7 operations, or at least most were until the media collapse that has been going on for quite some time, but came to public attention with the 2008 Great Recession and the cuts in advertising dollars that forced major layoffs that could no longer be hidden from public view. However, with rare exceptions in the current online environment, and virtually no exceptions when print distribution was the only way newspapers could distribute news to readers, almost nothing that reporters do is a legitimate “work of necessity or charity.” In today’s online environment I do not have a problem with — to cite actual examples — live reporting of Sunday crashes during winter storms that wrecked dozens of cars, shut down I-44 for many miles, and caused law enforcement to send out emergency alerts asking media to announce that vehicles needed to stay off the roadway unless they were emergency responders. Radio and TV reporters have been doing that for decades and newspapers are doing it now as well since we can distribute news online. I’ve taken emergency calls from police asking me to alert the public to a bomb threat that shut down a major roadway through town, and there have been fires that forced diversion of traffic off major roadways. But those are rare exceptions and sometimes a whole year goes by without a single legitimate work of necessity happening on any Sunday of the year. Almost nothing that happens on Sunday requires me to immediately report it — though my alarm is set for 12:30 a.m. each Monday and I spent many hours each Monday morning catching up on backed-up things I’ve missed for the previous 24 hours.
Over a 38-year career, I’ve had only a handful of situations in which an editor or publisher tried to get me to work on Sunday on things that weren’t legitimate. I refused. Reporting tends to be a young person’s job, which means lots of recent college graduates who want to party and get drunk every Friday night and are hung over or still partying on Saturday. Most editors were VERY glad to find somebody willing to sit in the newsroom and monitor the police scanner on Friday night and to cover things on Saturday when young people were hung over or still partying and older reporters wanted time with their families.
Being known for good work ethics, and being willing to work six days per week, considerably reduces the pressure to work on Sunday. I’ve certainly lost many promotion opportunities, including an editorship opportunity at a major English-language newspaper overseas. I’ve been turned down for more jobs than I can count for not being willing to work on Sunday. But those are both different issues than being fired for refusing to work on Sunday when the employer knew up front during the interview process that I wouldn’t take a job that required Sunday work.
An employer is under no obligation to hire somebody. To fire an already-hired employee who made clear up front before being hired that he wouldn’t work on certain days for religious reasons should be illegal because it is breaking the terms of employment to which the employer and employee previously agreed.
The Christian Sabbath is an interesting case. Confessionally, we believe that nature requires all men to set aside time to worship God, but that the proportion (one day in seven), and appointment (the first day of the week) are known by special revelation. Yet these specially revealed requirements are binding on all men. The “blue laws” recognize our natural obligation to worship. One reason for the magistrate to follow through on the non-natural specifications could be found in the civil duty to “protect the church of our common Lord.” The Confession is against violence on pretext of religion or irreligion, but does not regard the civil authority as a nursing father to every creed, let alone every view of (im)morality.
I am interested in how the Sunday Sabbath might be observed in Kuwait or another similar country. Official working days in Kuwait are Sunday to Thursday & Friday-Saturday is weekend days. (Before 2007 it was a Saturday-Wednesday workweek & Thursday/Friday weekend.) Can a Kuwait Christian work on Sunday after church (if in the morning) or before church (if in the evening)? Since a new day begins at sundown (biblically), can church be conducted Saturday night after sundown when the Sabbath officially begins? Or must it be after “when the sun had risen” on Sunday in keeping with Mark 16:2?
Hi Ronnie,
The same way Christians observed the Christian Sabbath before it was recognized as a legal, weekly holiday in the early 4th century. We rose very early, before the work day, to gather for public worship and then, after, after a long, arduous day, in the evening.
I am unaware, as a matter of history, that the pre-Constantinian Christians were scrupulous about the exact beginning or ending of the Sabbath.
Check out these resources on the Sabbath.
Thank you for replying with clarification. I think I had misunderstood the article to somehow imply that working on Sunday would be a violation of the fourth commandment.
Ordinarily, voluntarily working on the Sabbath is a violation of the 4th commandment but slaves have few options. Further, we distinguish between necessary labor (e.g., medical, public safety and the like) and servile labor. In a free economy, one need not sell suits on Sunday but we do need cops, firefighters, nurses, and the like on Sunday. Blessedly, under the US Constitution, Christians are still free to keep the Sabbath.
Tragically, there are places in the world where Christians are unable to keep the Sabbath and there have been times in Christian history when, like the Israelites in Egypt, we have been enslaved and otherwise forbidden to observe the creational/new-creational Sabbath pattern.
For more on this see the resources attached and see also the chapter in the Sabbath in Recovering the Reformed Confession. A link to this volume are under the article.