“[P]laintiff arranged for a substitute who voluntarily agreed to work [Plaintiff]’s shift that Sunday…. With a volunteer substitute available, [Defendant] would not have had to incur any cost requiring an employee to substitute for [Plaintiff], nor would [Defendant] necessarily be left short-handed.”  Davis v. Fort Bend County, 2014 WL 4209371 at *7 (5th Cir. 2014) (Prado, J.) (emphasis in original) (citing Antoine v. First Student, Inc., 713 F.3d 824, 839–40 (5th Cir. 2013).  The court found that the existence of a volunteer alone was sufficient evidence for the employer to make a reasonable accommodation: “Not only was [Plaintiff’s] ‘short period of absence’ minimal under Title VII, but [Plaintiff] … promised to report to work directly after the July 3rd event.”

Davis v. Fort Bend County, — F.3d –, 2014 WL 4209371, at *7 (5th Cir. Aug. 26, 2014) (Prado, J.).