Ricky Knight v. Leslie Thompson
796 F.3d 1289
11th Cir.2015Background
- Male inmates in Alabama Department of Corrections (ADOC) brought a RLUIPA challenge to ADOC’s short-hair policy, seeking a religious exemption to wear long, unshorn hair for Native American religious practice.
- District court entered judgment for ADOC after a trial with extensive factual findings about security, identification, hygiene, gang affiliation, and escape risks associated with long hair.
- Eleventh Circuit affirmed the district court in Knight v. Thompson, 723 F.3d 1275 (11th Cir. 2013) (Knight I).
- Supreme Court vacated and remanded Knight I for reconsideration in light of Holt v. Hobbs, 135 S. Ct. 853 (2015), which required a more “focused inquiry” and scrutiny of deference to prison officials in RLUIPA cases.
- On remand, the Eleventh Circuit considered supplemental briefs and reconducted analysis in light of Holt, concluding the record here contains detailed, non-conclusory evidence showing that allowing long, unshorn hair would undermine ADOC’s compelling interests.
- The court reinstated its prior opinion (with limited revision to Part III.B.ii), held that Holt did not change the outcome, and affirmed the district court’s judgment for the ADOC.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Holt’s requirement for a “focused inquiry” means the district court failed to scrutinize the ADOC’s policy as applied to long hair | Knight: district court did not perform the required focused, marginal-interest inquiry | ADOC: district court did perform a focused inquiry tailored to the requested exemption (long, unshorn hair) | Held: Court found the required focused inquiry was performed and the record supports it |
| Whether the district court gave improper “unquestioning deference” to prison officials, as criticized in Holt | Knight: district court deferred to ADOC testimony without demanding proof least restrictive means | ADOC: testimony was detailed, expert, and supported by anecdotal experience—not conclusory or speculative | Held: Court found ADOC witnesses provided substantive evidence; no improper unquestioning deference occurred |
| Whether evidence that many other prisons allow similar accommodations undermines ADOC’s claim that exemption is not feasible | Knight: ADOC failed to justify departure from widespread practice; other prisons’ policies show accommodation feasible | ADOC: other states’ policies may not permit entirely unshorn hair and the ADOC demonstrated specific security/hygiene risks here | Held: Court distinguished Holt—other systems’ practices were not clearly identical and ADOC provided persuasive, case-specific reasons for denying the exemption |
Key Cases Cited
- Knight v. Thompson, 723 F.3d 1275 (11th Cir. 2013) (original Eleventh Circuit opinion affirming district court’s judgment upholding ADOC short-hair policy)
- Holt v. Hobbs, 135 S. Ct. 853 (U.S. 2015) (Supreme Court requires focused, claimant-specific least-restrictive-means inquiry and warns against unquestioning deference to conclusory prison testimony)