A unanimous Supreme Court said on Tuesday that Arkansas can’t dictate the length of a beard maintained by a Muslim prisoner, after he made his own case initially to the Court using a handwritten form.
The case of Holt v. Hobbs was accepted in March 2014 after Gregory Holt, 38, sent the Supreme Court a 15-page publicly available form asking the nine Justices to accept his case. Arguments in the case were heard on October 7, 2014, and on Tuesday, the Court agreed with Holt.
Justice Samuel Alito said that Arkansas officials violated the Religious Land Use and Institutionalized Persons Act (or RLUIPA) when it couldn’t offer evidence the beard-length policy protected correctional officials or blocked the hiding of contraband.
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Alito also affirmed that RLUIPA doesn’t require a correctional facility to grant religious exemptions simply because a prisoner asks for one, or because other prisons grant exceptions. But he said that Arkansas couldn’t explain why its beard-length policy conflicted with “the vast majority of states” and the federal government, which permit prisoners to grow ½ inch beards for any reason.
“Such evidence requires a prison, at a minimum, to offer persuasive reasons why it believes it must take a different course,” Alito said.
Justice Sonia Sotomayor concurred with Alito’s opinion, repeating that the Court recognized that prison security is a compelling state interest. But Arkansas, she said, “offered little more than unsupported assertions in defense of its refusal of petitioner’s requested religious accommodation.”
Holt, also known as Abdul Malik Muhammad, is serving a life sentence for domestic violence and burglary, after he was convicted of cutting his girlfriend’s throat and stabbing her in the chest.
Holt carefully researched his case in Arkansas, and he included numerous prior court cases in his argument. Justice Alito had received the handwritten form in his role overseeing petitions from the Eighth Circuit, and referred it to the entire Court.
Noted University of Virginia law professor Douglas Laycock argued Holt’s case in front of the Supreme Court in October.
Holt said his Muslim beliefs require him to grow a beard. Arkansas corrections officials claimed their grooming policy prohibiting beards promotes hygiene and safety.
The Court previously blocked Arkansas from forcing Holt to shave the beard while his case was under consideration.
Scott Bomboy is the editor in chief of the National Constitution Center.
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