Holt v. Hobbes (2015)

In this Supreme Court case, Holt v. Hobbes, a convert to Islam who was incarcerated in the prison system claimed his faith compelled him to wear a beard. The wearing of beards was prohibited by prison regulations and officials cited security reasons for the rule and applied it without exception. Holt said as a Muslim he had to wear a beard, even though Islam does not require it.

Nevertheless, the Court sided with Holt stating the prison’s policy violated the Religious Land Use and Institutionalized Persons Act of 2000, which was enacted to provide a heightened protection for religious freedom already granted by the First Amendment. Further, the policy did not further the compelling interest in proscribing prisoners from hiding contraband, was not the least restrictive way to prevent prisoners from hiding contraband, and was not the least restrictive means of preventing prisoners from disguising identities.

The case is an important application of the RLUIPA statute by the Supreme Court. The Court rejected the prison’s insistence that it could prohibit Muslims from wearing beards where required by their religious beliefs, even if those beliefs are personal religious beliefs and not required by religious authorities. The Court found that the prison authorities’ reasons for prohibiting beards failed to meet the strict requirements of RLUIPA.