HOLT v. HOBBS

Legal Principle at Issue

Did the Arkansas Department of Correction's grooming policy substantially burden the prisoner's free exercise of religion?

Action

Reversed and remanded. Petitioning party received a favorable disposition.

Facts/Syllabus

A Muslim prisoner challenged a prison policy that denied a religious accommodation to allow a prisoner to grow a half-inch beard. He brought the challenge under the Religious Land Use and Institutionalized Persons Act (RLUIPA) against members of the staff, including the director, of the Arkansas Department of Correction. The United States District Court for the Eastern District of Arkansas adopted the position of a magistrate and dismissed with prejudice for failure to state a claim. He appealed. The United States Court of Appeals for the Eighth Circuit affirmed. The Supreme Court reversed.

Importance of Case

The prison's policy violated the Religious Land Use and Institutionalized Persons Act of 2000, which was enacted to provide a heightened protection for religious freedom already granted by the First Amendment. The policy did not further the compelling interest in proscribing prisoners from hiding contraband, was not the least restrictive way to preventing prisoners from hiding contraband, and was not the least restrictive means of preventing prisoners from disguising identities.