What is the standard for assessing failure to accommodate claims under the First Amendment?

Furthermore, courts have not frequently addressed the standard for assessing failure to accommodate claims under the First Amendment. See Brown v. Polk County, 61 F.3d 650, 654 (8th Cir.1995) ("In most of the cases alleging religious discrimination under Title VII, the employer is a private entity rather than a government, and the first amendment to the Constitution is therefore not applicable to the employment relationship."), cert. denied, --- U.S. ----, 116 S.Ct. 1042, --- L.Ed.2d ---- (1996).