Holt v. Hobbs

PETITIONER: Gregory Houston Holt
RESPONDENT: Ray Hobbs, Director, Arkansas Department of Corrections, et al.
LOCATION: Varner Supermax Unit

DOCKET NO.: 13-6827
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Eighth Circuit

CITATION: 574 US (2015)
GRANTED: Mar 03, 2014
ARGUED: Oct 07, 2014
DECIDED: Jan 20, 2015

ADVOCATES:
Anthony A. Yang - Assistant to the Solicitor General, Department of Justice, for the United States as amicus curiae supporting the petitioner
Douglas Laycock - for the petitioner
David A. Curran - for the respondent

Facts of the case

Gregory Holt (also known as Abdul Maalik Muhammad) was an inmate of the Arkansas Department of Corrections and a practicing Salafi Muslim. He sought an injunction and temporary relief from the enforcement of the Arkansas Department of Corrections' grooming policy, which allowed trimmed mustaches and quarter-inch beards for diagnosed dermatological problems but otherwise no facial hair. Holt argued that growing a beard was a necessary part of the practice of his religion, that the grooming policy significantly burdened his ability to do so, and that the grooming policy was therefore a violation of the Religious Land Use and Institutionalized Persons Act (RLUIPA). Holt was willing to limit his beard to a length of one-half inch as a form of compromise with the policy.

The district court granted temporary relief but then dismissed the complaint upon being presented with evidence of the other ways in which Holt was allowed to practice his religion and the extent to which the grooming policy was necessary to maintain prison security. The U.S. Court of Appeals for the Eighth Circuit affirmed.

Question

Does the Arkansas Department of Corrections grooming policy violate the Religious Land Use and Institutionalized Persons Act by preventing Holt from growing a one-half-inch beard in accordance with his religious beliefs?

Media for Holt v. Hobbs

Audio Transcription for Oral Argument - October 07, 2014 in Holt v. Hobbs

Audio Transcription for Opinion Announcement - January 20, 2015 in Holt v. Hobbs

John G. Roberts, Jr.:

Justice Alito has our opinion this morning in case 13-6827, Holt v. Hobbs.

Samuel A. Alito, Jr.:

This case involves a challenge to an Arkansas prison grooming policy that prohibits inmates from growing beards unless they have a particular dermatological condition.

Petitioner is an Arkansas inmate and devout Muslim who wishes to grow one-half inch beard in accordance with his religious beliefs.

After prison officials denied his request to grow beard, petitioner challenged the grooming policy under the Religious Land Use and Institutionalized Persons Act of 2000, RLUIPA for short, which is a federal law that prohibits the government from substantially burdening an inmate's religious exercise unless it demonstrates that the action constitutes the least restrictive means of furthering a compelling government interest.

The District Court denied petitioner relief and the Court of Appeals for the Eighth Circuit affirmed.

We now reverse and we hold that the policy as applied to the petitioner in this case violates RLUIPA.

Petitioner easily satisfied his initial burden of establishing that the grooming policy substantially burdens his religious exercise.

The policy requires him to shave his beard and thus engage in conduct that violates his religious beliefs.

If he disobeys that policy and grows a beard he will face significant disciplinary action.

Because the grooming policy puts petitioner to this choice, it substantially burdens his religious exercise and the prison does not argue otherwise.

The respondent prison officials failed to carry their burden of establishing that the grooming policy is the least restrictive means of furthering a compelling government interest.

The officials first argue that their policy furthers a compelling interest in preventing prisoners from hiding contraband.

We find it hard to take seriously the argument that this interest would be seriously compromised by allowing an inmate to grow a one-half inch beard and the officials have failed to show why simply searching a prisoner's beard is not a feasible less restrictive means to achieve this end.

The prison officials also argue that their growing policy furthers a compelling interest in preventing prisoners from disguising their identities.

While we agree that this is a compelling interest, the officials failed to establish that denying petitioner a beard is the least restrictive means of furthering that interest.

In particular, the prison could largely solve the identification problem by requiring that inmates be photographed both with and without beards.

The prison has also failed to explain why it cannot allow petitioner to grow a short beard for religious reasons but it can allow other inmates to grow one-quarter inch beards for medical reasons nor has it adequately explained why it cannot allow inmates to grow a short beard for religious reasons even though the vast majority of the states and the federal government allow inmates to grow such beards either for religious reasons or for any other reason.

Our decision is unanimous.

Justice Ginsburg has filed a concurring opinion in which Justice Sotomayor joins.

Justice Sotomayor has also filed a concurring opinion.

Sarah from Law Aspect

Hi there, would you like to get such a paper? How about receiving a customized one? Check it out https://goo.gl/9aavBA