Lester J. Smith v. Gregory Dozier, 13 F.4th 1319

Lester Smith, a Muslim serving life in a GDOC close‑security prison, sued under RLUIPA seeking to grow an untrimmed beard; GDOC’s post‑Holt policy permitted only a half‑inch beard.
GDOC presented evidence (witnesses and incidents) that untrimmed beards can hide contraband, be grabbed in assaults, and impede identification; Smith has an extensive disciplinary and violent‑offense record.
On remand after Holt v. Hobbs, the case went to a two‑day bench trial; the district court found GDOC’s evidence persuasive as to untrimmed beards but ruled the half‑inch policy violated RLUIPA and ordered a three‑inch beard exemption (a remedy Smith never requested).
Both parties appealed the three‑inch remedy. The Eleventh Circuit reviewed factual findings for clear error and legal conclusions de novo.
The court affirmed the district court’s factual finding that allowing an untrimmed beard (as requested) would be unmanageable/dangerous as applied to Smith, but vacated the three‑inch remedy because Holt limits courts to considering only the plaintiff’s proposed alternatives.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether GDOC’s half‑inch policy violated RLUIPA as applied to Smith (i.e., is the half‑inch rule the least restrictive means of furthering compelling interests)?	Smith: forbidding any trimming substantially burdens his religious exercise; he sought allowance to keep an untrimmed beard.	GDOC: security, contraband, identification, hygiene, staffing/manageability require strict beard limits.	Held: GDOC met its burden as applied to Smith; denying an untrimmed beard was not clearly erroneous.
Whether the district court could impose a three‑inch beard remedy not requested by Smith.	Smith: never proposed a three‑inch compromise; relief must be limited to the requested accommodation.	GDOC: opposed three‑inch remedy; argued security risks.	Held: District court erred to order a three‑inch beard—Holt requires courts to assess only the plaintiff’s proposed alternatives; three‑inch order vacated.
Whether the district court’s factual findings about untrimmed beards were clearly erroneous.	Smith: contested GDOC’s evidence and contended other jurisdictions accommodate untrimmed beards without problems.	GDOC: pointed to specific incidents, staffing shortages, and tractable risks in GDOC facilities.	Held: The circuit court found the district court’s factual findings that untrimmed beards posed plausible, unmanageable risks (particularly for Smith) were not clearly erroneous and are entitled to deference.

Holt v. Hobbs, 574 U.S. 352 (2015) (courts must evaluate the prison’s burden on a prisoner’s proposed accommodation; government must refute that proposed alternative).
Smith v. Owens, 848 F.3d 975 (11th Cir. 2017) (remanding for individualized, context‑specific RLUIPA inquiry post‑Holt).
Knight v. Thompson, 797 F.3d 934 (11th Cir. 2015) (deference to prison administrators where evidence supports security/discipline risks).
Cutter v. Wilkinson, 544 U.S. 709 (2005) (RLUIPA must be applied with sensitivity to prison security and deference to corrections expertise).
United States v. Wilgus, 638 F.3d 1274 (10th Cir. 2011) (government need not refute every conceivable alternative; analysis should focus on alternatives in the record).
Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682 (2014) (RLUIPA/RFRA principles on assessing burdens “to the person”).