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13-6827 HOLT V. HOBBS DECISION BELOW: 509 Fed.Appx. 561 ORDER OF 3/3/2014: LIMITED TO THE FOLLOWING QUESTION: “Whether the Arkansas Department of Correction’s grooming policy violates the Religious Land Use and Institutionalized Persons Act of 2000, 42 U.S.C. §2000cc et sec., to the extent that it prohibits petitioner from growing a one-half-inch beard in accordance with his religious beliefs.” CERT. GRANTED 3/3/2014 QUESTION PRESENTED: I. Whether the Arkansas Department of Corrections’ no beard grooming policy violates the Religious Land Use and Institutionalized Persons Act (RLUIPA). II. Whether a ½ inch beard would satisfy the security goals sought by the policy. III. Whether the no beard grooming policy violates Petitioner’s First Amendment right to practice Islam as he believes it is supposed to be practiced by the wearing of the beard. IV. That the United States Court of Appeals for the Eighth Circuit has decided that the no beard grooming policy does not violate the RLUIPA, but this Court should decide the matter since it has not done so and should rule whether grooming policies of any Department of Correction that do not allow for a religious exception exemption are constitutional. V. That the United States Court of Appeals for the Eighth Circuit’s decision in this case conflicts with other circuit’s rulings on the matter. VI. That the ADC grooming policy of no beards is not the least restrictive means of achieving the desired objective of staunching the flow of contraband and identifying prisoners in the event of an escape. LOWER COURT CASE NUMBER: 12-3185
In the case of Holt v. Hobbs, 2014, the U.S Supreme Court unanimously ruled in favor of Gregory Holt (also known as Abdul Maalik Muhammad), an Arkansas state prisoner and devout Muslim who sought to grow a half-inch beard for religious reasons. The Arkansas Department of Correction had denied his request citing security concerns under its grooming policy which prohibited beards except for diagnosed dermatological problems. The court held that this policy violated the Religious Land Use and Institutionalized Persons Act (RLUIPA) by imposing a substantial burden on Holt's religious exercise without demonstrating that denying him permission to grow a beard was the least restrictive means to furthering their compelling interest in prison safety and security.
In the case of Holt v. Hobbs, there was no dissenting opinion as the Supreme Court ruled unanimously in favor of Gregory Holt (also known as Abdul Maalik Muhammad), an Arkansas state prisoner. The court held that the Department of Correction’s grooming policy violated Holt's religious rights under the Religious Land Use and Institutionalized Persons Act (RLUIPA) by not allowing him to grow a half-inch beard in accordance with his Muslim faith.