HOLT v. HOBBS
Gregory Holt (also known as Abdul Maalik Muhammad) was an inmate of the Arkansas Department of Corrections and a practicing Salafi Muslim. He sought an injunction and temporary relief from the enforcement of the Arkansas Department of Corrections’ grooming policy, which allowed trimmed mustaches and quarter-inch beards for diagnosed dermatological problems but otherwise no facial hair. Holt argued that growing a beard was a necessary part of the practice of his religion, that the grooming policy significantly burdened his ability to do so, and that the grooming policy was therefore a violation of the Religious Land Use and Institutionalized Persons Act (RLUIPA). Holt was willing to limit his beard to a length of one-half inch as a form of compromise with the policy.
The district court granted temporary relief but then dismissed the complaint upon being presented with evidence of the other ways in which Holt was allowed to practice his religion and the extent to which the grooming policy was necessary to maintain prison security. The U.S. Court of Appeals for the Eighth Circuit affirmed.
Does the Arkansas Department of Corrections grooming policy violate the Religious Land Use and Institutionalized Persons Act by preventing Holt from growing a one-half-inch beard in accordance with his religious beliefs?