Holt v.Hobbs

RLUIPA does not allow a Department of Corrections to enforce a policy that prohibits an inmate from growing a half inch beard in accordance with his religious beliefs.

Petitioner is an inmate in custody of the Arkansas Department of Corrections ("DOC") and is also a devout Muslim. Petitioner wants to grow a half inch beard due to his religious beliefs. However, the state DOC does not allow inmates to grow facial hair absent a specific skin condition. Petitioner sued in federal district court, which found in favor of Respondent’s grooming policy; the Eighth Circuit affirmed the district court’s decision. The Court reversed and remanded the case, holding that the DOC’s policy violated the Religious Land Use and Institutionalized Persons Act ("RLUIPA"). The Court reasoned that while maintaining security in a prison is a compelling government interest, Respondent failed to show how the prohibition would further this interest. The Court further reasoned that the prohibition on facial hair was under-inclusive because of an exception that allowed for inmates with a skin condition to grow a fourth inch beard. The Court also reasoned that the interest in preventing contraband was not served by the prohibition on facial hair because there was no similar prohibition on the length of hair on the head. Even if the prohibition would serve this compelling interest, Respondent would have to prove that it was the least restrictive means of achieving the interest, but the Court reasoned that the interest could be achieved by simply checking a half inch beard, instead of prohibiting it.