Bolden v. Caravan Facilities Management, LLC, 112 F. Supp. 3d 785

Background

Bolden, a Missionary-Baptist pastor who observes Sabbath on Sundays, worked as a temporary janitor at a GM plant and was not a union member while employed through Pro Resources/Aramark; Aramark accommodated his Sundays-off request.
Caravan took over facility management in August 2012, hired Bolden as a probationary full‑time employee subject to the union’s collective bargaining agreement (CBA) and a neutral, rotating schedule allocating weekend work.
Bolden (no seniority) was placed on second shift and again requested every Sunday off; Caravan informed him the union would not permit an exception to the rotating schedule.
Bolden missed or called off several Sundays (some trades occurred), received an attendance warning, then called off three Sundays without replacements and was terminated during probation.
Bolden sued under Title VII for failure to reasonably accommodate his religious practice; Caravan moved for summary judgment arguing it provided a reasonable accommodation (rotating schedule + voluntary shift swaps) and that any alternative (every Sunday off) would impose undue hardship.
The district court granted summary judgment for Caravan, holding the neutral rotating schedule plus ability to swap was an appropriate accommodation and that requiring every Sunday off would impose more than a de minimis hardship given the CBA and seniority system; Bolden offered no viable alternative accommodation evidence.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Bolden established a prima facie Title VII failure‑to‑accommodate claim	Bolden asserted his Sabbath is religious, he requested Sundays off, and was fired for missing Sundays	Caravan conceded the religious nature and notice but contended it offered an accommodation and termination followed attendance policy	Court found prima facie elements met but resolved case on employer’s accommodation/undue hardship defenses
Whether Caravan’s neutral rotating schedule + voluntary swaps was a reasonable accommodation	Bolden challenged reasonableness as a jury question and disputed scope of Caravan’s communications	Caravan argued the rotating schedule with swap option is a recognized reasonable accommodation	Court treated rotating schedule/swapping as an acceptable accommodation and need not decide definitively because undue hardship alternative analysis disposed of the claim
Whether Caravan failed to engage in an interactive process	Bolden claimed Caravan’s communications caused a breakdown in the interactive process	Caravan said it discussed the matter with the union and informed Bolden of constraints; Bolden didn’t identify any missed alternative	Court found no material failure: Bolden did not show that further discussion would have produced a viable accommodation
Whether giving Bolden every Sunday off would impose undue hardship	Bolden offered no evidence showing the burden would be minimal or proposing feasible alternatives	Caravan showed that exempting Bolden would conflict with CBA/seniority or require lost productivity, overtime, or hiring replacements—costs exceeding de minimis	Court held that allowing every Sunday off would impose more than a de minimis hardship and granted summary judgment for Caravan

Key Cases Cited

Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard)
Trans World Airlines, Inc. v. Hardison, 432 U.S. 63 (Title VII does not require employer to violate CBA or incur more than de minimis cost to accommodate religious practice)
Porter v. City of Chicago, 700 F.3d 944 (burden‑shifting framework for religious accommodation claims)
Beadle v. Hillsborough Cnty. Sheriff’s Dep’t, 29 F.3d 589 (rotating shift plus authorized swaps can be reasonable accommodation)
Brener v. Diagnostic Ctr. Hosp., 671 F.2d 141 (same; rotating schedule and trade options adequate)
Rodriguez v. City of Chicago, 156 F.3d 771 (employees may seek transfers/shift changes as reasonable accommodation; context‑specific inquiry)
Adeyeye v. Heartland Sweeteners, LLC, 721 F.3d 444 (employer bears burden to prove undue hardship in context of seniority system)
EEOC v. Firestone Fibers & Textiles Co., 515 F.3d 307 (Title VII does not require employer to violate collective bargaining provisions)