BJC lauds High Court’s protection of  religious exercise, confirmation of the importance of RLUIPA in Holt v. Hobbs

By BJC Staff Reports

WASHINGTON — A unanimous Supreme Court declared Jan. 20 that a Muslim prisoner can exercise his religion by adhering to certain grooming standards, affirming a landmark 2000 law and agreeing with principles outlined in a brief signed by the Baptist Joint Committee.

In the decision for the Court in Holt v. Hobbs, Justice Samuel Alito wrote that the Arkansas Department of Correction (ADC) violated the Religious Land Use and Institutionalized Persons Act (RLUIPA) by denying a prisoner’s request to grow a one-half-inch beard in accordance with his religious beliefs.

RLUIPA provides enhanced protections in two areas where free exercise of religion can be a persistent problem: regulations of land use and institutions where individuals are confined in government custody. The BJC led a diverse coalition of religious and civil liberties groups in supporting RLUIPA, which Congress enacted in 2000.

“Everyone’s religious liberty is precious, but that of incarcerated persons is particularly fragile,” said BJC Executive Director J. Brent Walker. “Both RLUIPA and the Court’s opinion appropriately balance that right with the need of penal institutions to preserve prison safety and security.”

The BJC joined the American Jewish Committee and three other organizations in a friend-of-the-court brief in the case, defending the religious rights of Gregory H. Holt (also known as Abdul Maalik Muhammad), a practicing Muslim serving a life sentence in Arkansas. Holt said he has a religious obligation to maintain a beard, but the ADC has a grooming policy prohibiting facial hair other than neatly trimmed mustaches. It does allow one-quarter-inch beards for inmates with a diagnosed dermatological medical condition. 

The Court’s decision said Holt met all of the requirements of RLUIPA, showing that his desire to grow a beard was “grounded in a sincerely held religious belief” and that “the Department’s grooming policy substantially burdened that exercise of religion.”

“Part of RLUIPA’s purpose is to elevate religious needs to a similar level as other considerations,” according to the brief signed by the BJC. “In light of the high degree of protection that RLUIPA gives to inmates’ religious rights, it is illogical for the same institution to provide an almost identical accommodation for medical reasons, while denying that same accommodation for religious purposes.”

The Court emphasized that “although RLUIPA provides substantial protection for the religious exercise of institutionalized persons, it also affords prison officials ample ability to maintain security.”

While the Court recognized the interest in having a no-beards policy to prevent prisoners from hiding contraband, the decision said that “the argument that this interest would be seriously compromised by allowing an inmate to grow a ½-inch beard is hard to take seriously,” especially since prisoners are not required to have shaved heads or crew cuts. The Court noted that the ADC’s policy is “underinclusive” because it does not pursue the same objectives for “analogous nonreligious conduct,” allowing one-quarter-inch beards for dermatological conditions and permitting inmates to grow more than one-half-inch of hair on their heads.

More information on the case and the brief signed by the BJC is available online at

From the February 2015 Report from the Capital. Click here to read the next article.

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