## Facts

- Gregory Holt, an Arkansas state prisoner and practicing Salafi Muslim, sought to grow a 1/2-inch beard for religious reasons.
- The Arkansas Department of Correction grooming policy generally barred beards, allowing only 1/4-inch beards for inmates with certain medical conditions.
- Holt requested a religious accommodation to grow a 1/2-inch beard; prison officials denied the request.
- Prison officials asserted that beards could conceal contraband and that an inmate could shave to alter appearance after escape.
- Holt contended that contraband could not realistically be hidden in a short beard and noted the prison permitted medical beards and did not require shaved heads.
- Holt sued under the Religious Land Use and Institutionalized Persons Act (RLUIPA); the district court dismissed, and the Eighth Circuit affirmed, accepting the prison’s security rationale.
- The Supreme Court granted review.

## Issues

1. Whether prohibiting Holt from growing a 1/2-inch beard substantially burdened his religious exercise under RLUIPA.
2. If so, whether applying the no-beard policy to Holt was the least restrictive means of furthering compelling governmental interests in prison safety and security.

## Decision

- The Supreme Court unanimously reversed and remanded.
- The Court held that the grooming policy, as applied to prevent Holt from growing a 1/2-inch beard, violated RLUIPA.
- The Court found a substantial burden because the policy forced Holt to choose between violating his religious beliefs and facing disciplinary consequences.
- The Court accepted that contraband control and prisoner identification are compelling interests but held the prison did not show that banning Holt’s short beard was the least restrictive means.
- The Court pointed to less restrictive alternatives, including searching the beard (e.g., visual inspection or combing) and photographing inmates with and without beards for identification.
- The Court noted the policy’s underinclusiveness (medical beards permitted; no comparable limits on head hair) and the fact that many other prison systems allow short beards.

## Legal Principles

- RLUIPA bars imposing a substantial burden on an institutionalized person’s sincere religious exercise unless the government proves the burden furthers a compelling interest and is the least restrictive means.
- A substantial burden exists when a policy forces an adherent to choose between religious compliance and serious adverse consequences.
- RLUIPA protects religious exercise even if not mandated by religious authorities or universally practiced within a faith.
- The compelling-interest and least-restrictive-means inquiry must be applied to the particular claimant and the specific requested accommodation.
- Prison officials may receive respect for security judgments, but RLUIPA requires evidence-based justification; generalized assertions and “mere say-so” are insufficient when less restrictive measures are plausible.

## Conclusion

The Court held that Arkansas’s no-beard rule could not be enforced against Holt’s request for a 1/2-inch religious beard because the state failed to prove that a categorical prohibition was the least restrictive means to protect compelling security interests.


Holt v. Hobbs, 574 U.S. 352 (2015)