Holt v. Hobbs

574 U.S. 352 (2015)

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Nature of the Case

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Facts

The Religious Land Use and Institutionalized Persons Act of 2000, 42 U.S.C.S. § 2000cc et seq., (RLUIPA) prohibits a state or local government from taking any action that substantially burdens the religious exercise of an institutionalized person unless the government demonstrates that the action constitutes the least restrictive means of furthering a compelling governmental interest. P is an Arkansas inmate and devout Muslim who wishes to grow a 1/\2-inch beard in accordance with his religious beliefs. D prohibits its prisoners from growing beards, with the single exception that inmates with diagnosed skin conditions may grow 1/4-inch beards. P sought an exemption on religious grounds and, proposed a compromise under which he would be allowed to maintain a 1/2-inch beard. D denied his request. P filed a pro se complaint challenging the grooming policy under RLUIPA. The District Court granted P a preliminary injunction and remanded to a Magistrate Judge for an evidentiary hearing. D called two witnesses. Both expressed the belief that inmates could hide contraband in even a \1/2-inch beard, but neither pointed to any instances in which this had been done in Arkansas or elsewhere. Also, a prisoner who escaped could change his appearance by shaving his beard, and that a prisoner could shave his beard to disguise himself and enter a restricted area of the prison. The Magistrate Judge recommended that the preliminary injunction be vacated and that P’s complaint be dismissed for failure to state a claim on which relief can be granted. The District Court agreed and the Court of Appeals for the Eighth Circuit affirmed. It held that D had satisfied its burden of showing that the grooming policy was the least restrictive means of furthering its compelling security interests. The Supreme Court granted certiorari.