Holt v. Hobbs, 135 S. Ct. 853

Background

Gregory Holt (Abdul Maalik Muhammad), an Arkansas prison inmate and devout Muslim, sought permission to grow a 1/2‑inch beard as a religious exercise; prison policy generally prohibits facial hair except a neatly trimmed mustache and a 1/4‑inch beard for documented dermatological needs.
The Arkansas Department of Correction denied Holt’s request and threatened disciplinary action for noncompliance; Holt filed a pro se RLUIPA challenge in federal court.
A District Court granted a preliminary injunction but later (after evidentiary hearing) dismissed Holt’s complaint; the Eighth Circuit affirmed, deferring to prison officials’ security judgments.
At the hearing, prison witnesses testified that beards could hide contraband and enable disguises, but produced no examples of contraband hidden in a 1/2‑inch beard and acknowledged other searchable hiding places (head hair, clothing).
The Supreme Court held that the grooming policy, as applied to Holt, substantially burdened his religious exercise and that the Department failed to prove the policy was the least restrictive means of furthering compelling interests (contraband prevention and prisoner identification).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the grooming policy substantially burdens Holt's religious exercise under RLUIPA	Holt: requiring him to shave forces conduct contrary to sincere religious belief (growing a beard) and thus is a substantial burden	Dept.: alternatives exist (prayer rug, diet, other religious accommodations); no substantial burden	Held: Policy substantially burdens Holt — forcing abandonment of religiously required conduct is a substantial burden under RLUIPA
Whether the policy furthers a compelling governmental interest (contraband control) as applied to Holt	Holt: a 1/2‑inch beard is unlikely to conceal contraband; less restrictive searches (beard/comb searches, photos) suffice	Dept.: beards can hide razors/needles/SIM cards; searches risk guard safety; need broad prophylactic rule	Held: Dept. has compelling interest in stopping contraband but failed to show banning 1/2‑inch beards is the least restrictive means; offered no adequate reason why searches or other measures wouldn’t work
Whether the policy furthers a compelling governmental interest (identification/disguise prevention) as applied to Holt	Holt: dual photographs (bearded and clean‑shaven), periodic photos, and existing ID procedures address identification concerns	Dept.: shaving can quickly alter appearance and enable access/escape; particular prison layout (open barracks/fields) increases risk	Held: Dept. has compelling interest in identification but failed to prove the no‑beard rule is the least restrictive means; dual‑photo and other measures make the policy unjustified here
Whether deference to prison officials excuses failure to meet RLUIPA's least‑restrictive‑means test	Holt: deference is limited; RLUIPA requires evidence and demonstration that no less restrictive alternative exists	Dept.: courts should defer to prison expertise absent substantial contrary evidence	Held: Courts must respect expertise but not abdicate review; RLUIPA requires prisons to prove their rule is the least restrictive means and mere assertions are insufficient

Key Cases Cited

Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682 (2014) (RFRA/least‑restrictive‑means and substantial protection for religious exercise)
Gonzales v. O Centro Espírita Beneficente União do Vegetal, 546 U.S. 418 (2006) (RFRA requires focused, claimant‑specific inquiry into compelling interest)
Employment Div., Dept. of Human Resources v. Smith, 494 U.S. 872 (1990) (neutral, generally applicable laws and Free Exercise analysis)
City of Boerne v. Flores, 521 U.S. 507 (1997) (limits on Congress’s enforcement powers under Fourteenth Amendment; context for RLUIPA enactment)
Cutter v. Wilkinson, 544 U.S. 709 (2005) (RLUIPA in prison context; context matters and deference to prison administrators)
Church of Lukumi Babalu Aye, Inc. v. Hialeah, 508 U.S. 520 (1993) (underinclusiveness and strict scrutiny in religious‑exercise challenges)
Sherbert v. Verner, 374 U.S. 398 (1963) (compelling interest/strict scrutiny framework)
Wisconsin v. Yoder, 406 U.S. 205 (1972) (balancing of religious exercise against governmental interests)
United States v. Playboy Entertainment Group, Inc., 529 U.S. 803 (2000) (least‑restrictive‑means principle and invalidation of broader regulations when narrower options exist)
Procunier v. Martinez, 416 U.S. 396 (1974) (policies at other institutions are relevant when assessing need for restrictions)