Holt v. Hobbs

Supreme Court of the United States
135 S. Ct. 853, 2015 U.S. LEXIS 626, 190 L. Ed. 2d 747 (2015)

ELI5:

Rule of Law:

Under the Religious Land Use and Institutionalized Persons Act (RLUIPA), a prison policy that substantially burdens an inmate's sincere religious exercise violates the Act unless the government proves the policy is the least restrictive means of furthering a compelling governmental interest.

Facts:

Gregory Holt is an inmate in the Arkansas Department of Correction and a devout Muslim.
Holt's religious beliefs require him to grow a beard.
The Arkansas Department of Correction maintains a grooming policy that prohibits inmates from growing beards, with an exception for a ¼-inch beard for diagnosed dermatological problems.
Holt sought a religious accommodation, proposing a compromise to grow a ½-inch beard.
Prison officials denied Holt's request and informed him he would face disciplinary action if he did not comply with the grooming policy.

Procedural Posture:

Gregory Holt filed a pro se complaint in the U.S. District Court for the Eastern District of Arkansas, alleging the prison's grooming policy violated RLUIPA.
The District Court initially granted Holt a preliminary injunction.
Following an evidentiary hearing, a Magistrate Judge recommended dismissing the complaint.
The District Court adopted the Magistrate Judge's recommendation and dismissed Holt's complaint.
Holt, as appellant, appealed to the U.S. Court of Appeals for the Eighth Circuit.
The Court of Appeals affirmed the District Court's dismissal, siding with the Arkansas Department of Correction, the appellee.
The U.S. Supreme Court granted Holt's petition for a writ of certiorari.

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Issue:

Does a prison grooming policy that prohibits an inmate from growing a ½-inch beard in accordance with his sincere religious beliefs violate the Religious Land Use and Institutionalized Persons Act (RLUIPA)?

Opinions:

Majority - Justice Alito

Yes, the prison grooming policy violates RLUIPA as applied to Holt. The policy substantially burdens Holt's religious exercise by forcing him to choose between his faith and disciplinary action. The Department of Correction failed to meet its burden of proving that a total ban on beards was the least restrictive means of furthering its compelling interests in security. The Department's arguments about hiding contraband in a ½-inch beard were unpersuasive, and it failed to show why less restrictive alternatives, such as searching the beard or taking dual photographs of the inmate (one with and one without a beard), would be ineffective. The policy was also underinclusive, as it permitted inmates to have long hair on their heads and ¼-inch beards for medical reasons, both of which pose similar or greater security risks.

Concurring - Justice Ginsburg

Yes. Justice Ginsburg joins the Court's opinion, writing separately to note that, unlike the religious exemption at issue in Burwell v. Hobby Lobby, accommodating Holt's religious belief in this case would not detrimentally affect any third parties.

Concurring - Justice Sotomayor

Yes. While courts should give deference to the expertise of prison officials, that deference is not absolute. RLUIPA requires the government to provide more than 'unsupported assertions' or 'mere speculation' to justify burdening religious exercise. The Department's failure to demonstrate why the less restrictive alternatives identified by Holt were insufficient to achieve its security interests is fatal to its position. The government must refute the specific less restrictive alternatives offered by the challenger.

Analysis:

This case significantly reinforces the strength of RLUIPA's protections for prisoners' religious rights, establishing that prison officials' claims of security concerns are not entitled to unquestioning deference. The Court clarified that the 'least restrictive means' test is an exceptionally demanding standard that requires prisons to provide concrete proof, not mere assertions, that their policies are necessary and that no viable alternatives exist. This decision places a heavy evidentiary burden on correctional facilities to justify any policy that substantially burdens religious exercise and emboldens inmate challenges to such policies across the country.

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