Holt v. Hobbs

Holt v. Hobbs, 574 U.S. ___ (2015), was an American legal case in which the Supreme Court unanimously ruled that an Arkansas prison policy which prohibited a Muslim prisoner from growing a short beard in accordance with his religious beliefs violated the Religious Land Use and Institutionalized Persons Act (RLUIPA).[1]

Holt v. Hobbs
Argued October 7, 2014
Decided January 20, 2015
Full case nameGregory Houston Holt, A/K/A Abdul Maalik Muhammad, Petitioner v. Ray Hobbs, Director, Arkansas Department of Correction, et al., Respondents
Docket no.13-6827
Citations574 U.S. ___ (more)
135 S. Ct. 853; 190 L. Ed. 2d 747
ArgumentOral argument
Case history
Prior509 F. App'x 561 (8th Cir. 2012) (per curiam); cert. granted, 134 S. Ct. 1490 (2014).
Holding
An Arkansas prison policy which prohibited a Muslim prisoner from growing a short beard in accordance with his religious beliefs violated the Religious Land Use and Institutionalized Persons Act
Court membership
Chief Justice
John Roberts
Associate Justices
Antonin Scalia · Anthony Kennedy
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Case opinions
MajorityAlito, joined by unanimous
ConcurrenceGinsburg, joined by Sotomayor
ConcurrenceSotomayor
Laws applied
42 U.S.C. § 2000cc et seq.

Background

Gregory Holt (also known as Abdul Maalik Muhammad) was a prisoner in the Arkansas Department of Corrections. Holt was also a devout Muslim who believed, based on hadith, that his faith obliged him to leave his beard entirely uncut.[2]:5–7 However, Arkansas policy prohibited inmates to grow any beards (except to a length of a quarter inch when medically required).

Holt requested an exemption from the no-beards policy through the prison grievance process. Based upon a case ordering California officials to allow Muslim prisoners to grow a half-inch beard, Holt requested permission to grow a half-inch beard only, as a "compromise".[2]:7 His request was rejected.

In lower courts

Holt then filed a motion in court to require Arkansas allow him to grow a half-inch beard, arguing that he deserved an exception under the Religious Land Use and Institutionalized Persons Act. He argued pro se that he was entitled to an exemption because Arkansas's policy was not, as required under RLUIPA, the "least restrictive means" for Arkansas to further its interests.

The magistrate initially recommended the motion be denied, but the District Court temporarily granted his request and sent the matter back to the magistrate for a hearing. At the hearing, Holt testified that it was impossible to hide anything in his beard. Two prison officials testified in response that inmates could hide contraband in half-inch beards, that an escaped prisoner with a beard could change his appearance by shaving his beard, and that it would be difficult to consistently measure half-inch beards. The magistrate ultimately deferred to the judgment of the prison officials, relying on Eighth Circuit precedent, and recommended that Holt's motion be denied. The District Court adopted the magistrate's recommendations, and the Eighth Circuit affirmed.[2]:8–11

Holt then filed a pro se petition for a writ of certiorari and a request to proceed in forma pauperis.[3] On March 3, 2014, the Supreme Court agreed to hear the case.[4]

Supreme Court decision

The majority opinion written by Alito said that RLUIPA does not require a prison to grant religious exemptions simply because a prisoner asks or because other prisons do.[5] However, Arkansas officials offered no evidence that a short beard presented security risks or could serve as a hiding place for contraband, as the officials argued. Arkansas had not overcome the high hurdles set by the law: that policymakers may not burden a person’s exercise of religion unless they can show a compelling governmental interest and that the policy was the least-restrictive means of achieving that goal. In a concurrence, Justice Ginsburg, contrasting the case with Burwell v. Hobby Lobby, said accommodating Holt’s request "would not detrimentally affect others who do not share petitioner’s belief."[6] In a separate concurrence, Justice Sotomayor disagreed with the majority's application of RLUIPA, but did agree that Arkansas officials did not adequately respond to Holt's request to keep a beard.[5]

See also

References
  1. Sherman, Mark (20 January 2015). "Supreme Court rules for bearded Muslim inmate". Associated Press. Archived from the original on 21 January 2015. Retrieved 20 January 2015.
  2. "Brief for the Petitioner" (PDF). May 22, 2014. Retrieved November 30, 2014.
  3. "Petition for Writ of Certiorari" (PDF). September 27, 2013. Retrieved November 30, 2014.
  4. "Docket No. 13-6827, Gregory Houston Holt, aka Abdul Maalik Muhammad, Petitioner v. Ray Hobbs, Director, Arkansas Department of Correction, et al". Retrieved November 30, 2014.
  5. Holt v. Hobbs, No. 13-6827, 574 U.S. ___ (2015).
  6. "Religious Liberty: Of beards and brevity". The Economist. 2015-01-21. Retrieved 30 January 2015.

Further reading
  • Beydoun, Khaled A. (2015). "Islam Incarcerated: Religious Accommodation of Muslim Prisoners Before Holt v. Hobbs". Working paper. SSRN 2561845.
  • Shapiro, David M. (2015). "To Seek a Newer World: Prisoners' Rights at the Frontier". Northwestern Public Law Research Paper No. 15-48. SSRN 2707744.
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