Holt v. Hobbs: Petitioner's RLUIPA Claim Analyzed

Introduction and Legal Question

The central legal question examined here is whether the Arkansas Department of Corrections' grooming policy violates the Religious Land Use and Institutionalized Persons Act (RLUIPA) by preventing Gregory Holt from growing a one-half inch beard in accordance with his sincere religious beliefs. This paper presents and analyzes the petitioner's side of the case.

Facts of the Case

The petitioner, Gregory Holt — also known as Abdul Maalik Muhammad — is an inmate at the Arkansas Department of Corrections and a practicing Salafi Muslim. He filed suit seeking an injunction and temporary relief from the Department's grooming policy, which permitted only neatly trimmed mustaches and, for inmates with a physician-diagnosed dermatological condition, beards of no more than one-quarter inch in length. Holt claimed that this grooming policy violated RLUIPA. As a compromise, Holt offered to limit his beard to one-half inch.

The district court initially granted temporary relief but ultimately dismissed the complaint, noting that Holt's religion had been afforded extensive practice rights and that the grooming policy was necessary for maintaining prison security. The U.S. Court of Appeals for the Eighth Circuit affirmed this decision.

Arkansas Grooming Policy and RLUIPA

The Arkansas Department of Corrections grooming policy, Administrative Direction 90-04, 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.)

Section 3 of RLUIPA provides 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.)

Comparative Prison Practices Across Jurisdictions

The Supreme Court case record provides important comparative context. As stated on page 24 of the court document:

"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. 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.)

This comparative evidence is significant because it demonstrates that a substantial majority of American correctional systems have determined that permitting inmate facial hair does not pose an unacceptable security risk — undermining the State's position that its restrictive policy represents the least restrictive means of achieving its stated interest.

References

Holt v. Hobbs, No. 13-6827. Supreme Court of the United States.

Petitioner's Supplemental Brief. Holt v. Hobbs, No. 13-6827. Supreme Court of the United States.

Holt v. Hobbs (2014). Legal Information Institute. Retrieved from: http://www.law.cornell.edu/supct/cert/13-6827