Ricky Knight v. Leslie Thompson
2015 U.S. App. LEXIS 13667
| 11th Cir. | 2015Background
- Male Alabama inmates (Plaintiffs) seek religious exemption to ADOC policy requiring male hair be "off neck and ears" to wear long hair for Native American religious reasons; ADOC grants no exemptions.
- Procedural history: suit filed 1993; after appeals and remand under RLUIPA, district court conducted full evidentiary hearing and bench trial on remand and found for ADOC; appeal followed.
- Plaintiffs presented undisputed evidence that long hair is central to their faith and that many jurisdictions permit long hair or religious exemptions; offered expert testimony that photo manipulation and self-searching could mitigate ADOC concerns.
- ADOC witnesses (wardens and former corrections director Angelone) testified long hair allows concealment of contraband/weapons, impedes identification (including post-escape), increases hair-pulling in fights, hides infections, slows searches, and undermines uniform discipline—supported by specific anecdotes and institutional data on overcrowding/understaffing.
- Magistrate Judge and District Court credited ADOC's factual findings (overcrowding, increased disciplinary incidents, security risks) and concluded ADOC met RLUIPA burden that the exceptionless short-hair policy furthers compelling interests and is the least restrictive means.
- Eleventh Circuit affirms: accepts substantial-burden on religion but holds ADOC carried its burden under RLUIPA; practices of other jurisdictions and female grooming rules did not show a less restrictive feasible alternative.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ADOC hair-length rule substantially burdens religious exercise | Long hair is central to Native American belief; rule substantially burdens exercise | ADOC did not dispute substantial burden | Court: burden is established (plaintiffs prevail on prima facie burden) |
| Whether ADOC's aims are compelling (security, discipline, hygiene, safety, public ID) | Plaintiffs challenged factual basis for ADOC's security claims | ADOC: compelling interests supported by corrections experience, incidents, overcrowding/staffing evidence | Court: ADOC's interests are compelling and supported by record |
| Whether ADOC's exceptionless short-hair rule is least restrictive means under RLUIPA | Proposed alternatives (religious exemption with self-searches, Photoshop/photo manipulation) suffice and are less restrictive | ADOC: alternatives inadequate—self-searches can be manipulated, photo tools don’t help in-prison ID, other risks (gang ID, hair-pulling, hidden infections) remain | Court: ADOC met its burden; rule is least restrictive means as applied to plaintiffs |
| Whether practices of other jurisdictions or female grooming policies show less restrictive options | Widespread permissive policies and female shoulder-length allowance show feasible alternatives | ADOC: other jurisdictions choose to accept different risks; male/female differences justified by record | Court: practices elsewhere and female rules non-dispositive; ADOC may treat sexes differently given security differences; equal protection claim rejected |
Key Cases Cited
- Harris v. Chapman, 97 F.3d 499 (11th Cir. 1996) (upholding exceptionless short-hair prison grooming policy under RFRA/RLUIPA framework)
- Cutter v. Wilkinson, 544 U.S. 709 (2005) (RLUIPA protects institutionalized persons but courts must give due deference to prison administrators on security concerns)
- Rich v. Secretary, Florida Dept. of Corrections, 716 F.3d 525 (11th Cir. 2013) (policies based on speculation or post-hoc rationalizations insufficient under RLUIPA)
- Lawson v. Singletary, 85 F.3d 502 (11th Cir. 1996) (standard of review for RFRA/RLUIPA issues and mixed fact-law review)
- Fegans v. Norris, 537 F.3d 897 (8th Cir. 2008) (upholding differential grooming rules for men and women in prison when supported by record)
- Lathan v. Thompson, [citation="251 F. App'x 665"] (11th Cir. 2007) (prior panel decision remanding hair-length claims for factual development under RLUIPA)