Home › Case briefs › Constitutional Law

Holt v. Hobbs

Supreme Court of the United States · 2015 · Constitutional Law

Constitutional LawReligious Land Use and Institutionalized Persons Act (RLUIPA)Prisoners' religious exerciseRLUIPAsubstantial burdencompelling governmental interestleast restrictive meansprison security

Facts

Gregory Holt, an Arkansas inmate and devout Muslim, believed his faith required him not to trim his beard, but he sought a compromise allowing him to grow only a 1/2-inch beard. Arkansas prison policy prohibited facial hair except for a neatly trimmed mustache and allowed only a 1/4-inch beard for inmates with certain dermatological conditions. Prison officials denied Holt's request and asserted that beards could hide contraband and allow inmates to alter their appearance by shaving. At the evidentiary hearing, the Department's witnesses identified no instance in Arkansas or elsewhere of contraband being hidden in a 1/2-inch beard and could not explain why photographs without beards would not address identification concerns.

Issue

Whether Arkansas's grooming policy, as applied to prevent Holt from growing a 1/2-inch beard for religious reasons, violated RLUIPA. More specifically, the question was whether the policy substantially burdened his religious exercise and, if so, whether the Department proved that denying the exemption was the least restrictive means of furthering compelling security interests.

Rule

Under RLUIPA, a claimant must show that the requested practice is grounded in a sincerely held religious belief and that the government has substantially burdened that religious exercise. The burden then shifts to the government to prove that applying the challenged rule to the particular claimant furthers a compelling governmental interest and is the least restrictive means of doing so; courts must not grant unquestioning deference to prison officials, and the availability of other religious practices does not defeat a substantial-burden showing.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

At a correctional facility in Toledo, Ohio, Malik Jensen sincerely believes his religion requires him to wear a small knitted cap during waking hours. The prison bans all head coverings outside cells and warns that if Malik keeps wearing the cap, he will lose commissary privileges and be placed in disciplinary segregation.

If Malik sues under RLUIPA, which is the strongest argument that the policy substantially burdens his religious exercise?

Explanation. Under the majority opinion, a substantial burden exists when the government puts the claimant to the choice of engaging in conduct that seriously violates his religious beliefs or facing disciplinary consequences. RLUIPA asks whether the challenged policy substantially burdens the specific religious exercise at issue, not whether the claimant can practice religion in other ways or whether the practice is universally required within the faith.