Supreme Court Case Holt v. Hobbs

HOLT V. HOBBS: PETITIONER'S SIDE OF THE CASE

The objective of this study is to answer the legal question of whether 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.

Facts of the Case

The petitioner in this case, Gregory Holt is who also known as Abdul Maalik Muhammad, an inmate at the Arkansas Department of Corrections and a Salafi Muslim filed seeking an injunction and requesting temporary relief from the Arkansas Department of Corrections policy on grooming reported to allow mustaches that were trimmed and beard that were one-quarter inch in length when dermatological problems were diagnosed by the prison's physicians. Holt claimed that the grooming policy violated the Religious Land Use and Institutionalized Persons Act (RLUIPA). Holt had agreed to limit the length of his beard to one-half inch in compromise with the prison policy. Temporary relief was granted by the district court however, the complaint was dismissed when noted by the court that the religion of Holt had been given extensive practice rights and that the grooming policy was such that was required for prison security maintenance. This decision was affirmed by the U.S. Court of Appeals for the Eighth Circuit.

The Arkansas Department of Corrections grooming policy states "No inmates will be permitted to wear facial hair other than the neatly trimmed moustache that does not extend beyond the corner of the mouth or over the lips. Medical staff may prescribe that inmates with a diagnosed dermatological problem may wear facial hair no longer than one quarter of an inch." (Administrative Direction 90-04 cited in: Supreme Court of the United States, No. 13-6827, p. 1) it is stated that it is provided in Section 3 of the RLUIPA that "no state or local government shall impose a substantial burden on the religious exercise of a person residing in or confined to an institution unless the government shows that the burden furthers a compelling governmental interest and does so by the least restrictive means." (Section 2000cc-1(a)(1)-(2) cited in Supreme Court of the United States, No. 13-6827, p. 1)

It is stated in the court document detailing this case on page 24 as follows: Of the forty-one jurisdictions without length limitations, thirty-four permit beards for all prisoners; seven (Arizona, New Mexico, New York, North Dakota, Ohio, Pennsylvania, and West Virginia) restrict beards but allow religious exemptions. Two of these seven permit all prisoners to grow beards longer than what petitioner seeks -- an inch in New York and three inches in Pennsylvania; the religious exemption is for prisoners who require even longer beards. Id. At 968-69. And since Professor Sidhu's article was published, Ohio amended its rules and now permits beards for all prisoners, with no length limits. Ohio Admin. Code 5120-9-25(F)." (Supreme Court of the United States, No 13-6827, p. 24)

However, it was the contention of the Arkansas Department of Corrections that its' grooming policy held a compelling governmental interest in that the grooming policy was such that enabled the Arkansas Department of Corrections to identify prisoners in addition to ensuring safety in the prison. While other prisons had chosen to allow the growth of facial hair, it was not required that the Arkansas Department of Corrections take on the same risks as other prisons had agreed to take on by allowing the growth of facial hair.