Holt v. Hobbs - 574 U.S. 352, 135 S. Ct. 853 (2015)

Rule:

The Religious Land Use and Institutionalized Persons Act of 2000, 42 U.S.C.S. § 2000cc et seq., prohibits a state or local government from taking any action that substantially burdens the religious exercise of an institutionalized person unless the government demonstrates that the action constitutes the least restrictive means of furthering a compelling governmental interest.

Facts:

Section 3 of the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA) provides that “no government shall impose a substantial burden on the religious exercise” of an institutionalized person unless the government demonstrates that the burden “is the least restrictive means of furthering a compelling governmental interest.” 42 U.S.C. §2000cc-1(a). Petitioner Gregory Holt, also known as Abdul Maalik Muhammad, is an Arkansas inmate and devout Muslim who wishes to grow a 1/2-inch beard in accordance with his religious beliefs. Respondent Arkansas Department of Correction (Department) prohibits its prisoners from growing beards, with the single exception that inmates with diagnosed skin conditions may grow 1/4-inch beards. Holt, sought an exemption on religious grounds and, although he believes that his faith requires him not to trim his beard at all, he proposed a compromise under which he would be allowed to maintain a 1/2-inch beard. Prison officials denied his request, and Holt sued in Federal District Court. At an evidentiary hearing before a Magistrate Judge, Department witnesses testified that beards compromised prison safety because they could be used to hide contraband and because an inmate could quickly shave his beard to disguise his identity. The Magistrate Judge recommended dismissing petitioner's complaint, emphasizing that prison officials are entitled to deference on security matters and that the prison permitted petitioner to exercise his religion in other ways. The District Court adopted the recommendation in full, and the Eighth Circuit affirmed, holding that the Department had satisfied its burden of showing that the grooming policy was the least restrictive means of furthering its compelling security interests, and reiterating that courts should defer to prison officials on matters of security.

Issue:

Did the state prison's policy preventing an inmate from growing a short beard violate the Religious Land Use and Institutionalized Persons Act of 2000, 42 U.S.C.S. § 2000cc et seq.?

Answer:

Yes

Conclusion:

The court held that a state prison's policy preventing an inmate from growing a short beard violated the Religious Land Use and Institutionalized Persons Act of 2000, 42 U.S.C.S. § 2000cc et seq., since it was undisputed that the policy substantially burdened the inmate's sincerely held religious belief that a beard was required by his religion, and there was no showing that the policy was the least restrictive means of furthering compelling prison interests. The unlikelihood of hiding contraband in a short and easily searched beard precluded a showing of a compelling interest, and the prison did not require inmates to have short head hair. The policy was not the least restrictive means of furthering the prison's interest in inmate identification, since the inmate could be photographed both with and without a beard and periodically thereafter as commonly occurred at other prisons.