21 January 2015

Law in Plain English: Holt v. Hobbs

This is one in a series of posts designed to describe court decisions in plain English. For more detail and background on the legal issues, see the link to the case below. For similar posts, click here.

SCOTUSblogHolt v. Hobbs

Argument: Oct 7 2014 (Aud.)

Hobbs filed his own, handwritten cert petition.
Background: Gregory Holt (also known as Abdul Maalik Muhammad), an inmate under the supervision of the Arkansas Department of Corrections (ADC), filed a lawsuit challenging the ADC's grooming policy. The policy allowed trimmed mustaches but otherwise no facial hair, with quarter-inch beards permitted for a diagnosed dermatological problems. Holt alleged that the policy substantially burdened his ability to practice his religion, in violation of the Religious Land Use and Institutionalized Persons Act (RLUIPA). The district court initially granted temporary injunctive relief, but vacated its order and dismissed the complaint after hearing evidence of Holt's other religious accommodations and the ADC's justifications for the grooming policy in terms of prison security. The Eighth Circuit affirmed, finding that ADC's grooming policy was the least restrictive means of furthering a compelling penological interest.

Issue: The question before the Court is whether the Arkansas Department of Correction's grooming police policy violates the Religious Land Use and Institutionalized Persons Act (RLUIPA) of 2000, 42 U.S.C. § 2000cc et. seq., to the extent that it prohibits petitioner from growing a one-half-inch beard in accordance with his religious beliefs.

Holding: In a unanimous decision, the Supreme Court ruled that the Department’s grooming policy violates RLUIPA insofar as it prevents petitioner from growing a ½-inch beard in accordance with his religious beliefs. While the Department has a compelling interest in regulating contraband, its argument that this interest is compromised by allowing an inmate to grow a ½-inch beard is unavailing, especially given the difficulty of hiding contraband in such a short beard and the lack of a corresponding policy regulating the length of hair on the head.

Gregory Holt, also known as Abdul Muhammad

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