Supreme Court Dogs - Holt v. Hobbs #RealAnimalsFakePaws #PawJustice

Case Summary

The argument concerned whether Arkansas violated the Religious Land Use and Institutionalized Persons Act (RLUIPA) by refusing to let Muslim prisoner Gregory Holt grow a half-inch beard for religious reasons.

Arguments

Holt’s lawyer argued that RLUIPA required Arkansas to show that its restriction served a compelling interest and was the least restrictive means of doing so. He said the state’s evidence was largely speculative: it offered no concrete examples of contraband hidden in beards, and many other prison systems allowed beards. He also argued that the prison’s medical shaving accommodation and its allowance of longer hair weakened its security justifications. Courts should give prison officials appropriate deference, he maintained, but that deference should reflect the quality and evidentiary basis of their explanations.

A lawyer for the United States, supporting Holt, agreed that prison security was a compelling interest but argued that Arkansas still had to justify its specific policy under RLUIPA. The fact that many other prison systems permitted beards was not conclusive, he said, but it made Arkansas’s burden harder to meet. He acknowledged that longer beards might pose different risks.

Arkansas argued that beards could make identification harder and potentially conceal contraband. The state emphasized the layout of its maximum-security prison, where groups of inmates moved between housing and work areas, and said quick identification was especially important there. It contended that officials’ informed judgments deserved deference and that rules should be practical to administer. Arkansas also disputed the comparison with medical shaving, describing it as a method of shaving rather than permission to keep a beard.

Questions from the Justices

The justices pressed Holt’s side on how courts could draw a workable line between a half-inch beard and longer beards, and whether a limited request could establish a general rule. They also asked how religious accommodation should be balanced against even small security risks.

The justices questioned Arkansas on whether it had shown actual or sufficiently supported risks, why head hair was treated differently, and whether the state’s arguments were consistent with RLUIPA’s demanding standard. In rebuttal, Holt’s lawyer said the record contained little concrete evidence and that deference could not replace the statute’s requirements.

Presenters and Contributors

• Douglas Laycock, for Holt
• Ian H. Gershengorn, for the United States as amicus curiae supporting Holt
• David R. Curran, for Arkansas
• Chief Justice John Roberts and Justices Antonin Scalia, Anthony Kennedy, Ruth Bader Ginsburg, Stephen Breyer, Samuel Alito, Sonia Sotomayor, and Elena Kagan