Holt v. Hobbs

Last updated

Holt v. Hobbs
Seal of the United States Supreme Court.svg
Argued October 7, 2014
Decided January 20, 2015
Full case nameGregory Houston Holt, A/K/A Abdul Maalik Muhammad, Petitioner v. Ray Hobbs, Director, Arkansas Department of Correction, et al., Respondents
Docket no. 13-6827
Citations574 U.S. 352 ( more )
135 S. Ct. 853; 190 L. Ed. 2d 747
Argument Oral argument
Case history
Prior509 F. App'x 561 (8th Cir. 2012) (per curiam); cert. granted, 571 U. S. 1236 (2014).
Holding
An Arkansas prison policy which prohibited a Muslim prisoner from growing a short beard in accordance with his religious beliefs violated the Religious Land Use and Institutionalized Persons Act
Court membership
Chief Justice
John Roberts
Associate Justices
Antonin Scalia  · Anthony Kennedy
Clarence Thomas  · Ruth Bader Ginsburg
Stephen Breyer  · Samuel Alito
Sonia Sotomayor  · Elena Kagan
Case opinions
MajorityAlito, joined by unanimous
ConcurrenceGinsburg, joined by Sotomayor
ConcurrenceSotomayor
Laws applied
42 U.S.C.   § 2000cc et seq.

Holt v. Hobbs, 574 U.S. 352 (2015), was an American legal case in which the Supreme Court unanimously ruled that an Arkansas prison policy which prohibited a Muslim prisoner from growing a short beard in accordance with his religious beliefs violated the Religious Land Use and Institutionalized Persons Act (RLUIPA). [1]

Contents

Background

Gregory Holt (also known as Abdul Maalik Muhammad) was a prisoner in the Arkansas Department of Corrections. Holt was also a Muslim who believed, based on hadith, that his faith obliged him to leave his beard entirely uncut. [2] :5–7 However, Arkansas policy prohibited inmates to grow any beards (except to a length of a quarter inch when medically required).

Holt requested an exemption from the no-beards policy through the prison grievance process. Based upon a case ordering California officials to allow Muslim prisoners to grow a half-inch beard, Holt requested permission to grow a half-inch beard only, as a "compromise". [2] :7 His request was rejected.

In lower courts

Holt then filed a motion in court to require Arkansas allow him to grow a half-inch beard, arguing that he deserved an exception under the Religious Land Use and Institutionalized Persons Act. He argued pro se that he was entitled to an exemption because Arkansas's policy was not, as required under RLUIPA, the "least restrictive means" for Arkansas to further its interests.

The magistrate initially recommended the motion be denied, but the District Court temporarily granted his request and sent the matter back to the magistrate for a hearing. At the hearing, Holt testified that it was impossible to hide anything in his beard. Two prison officials testified in response that inmates could hide contraband in half-inch beards, that an escaped prisoner with a beard could change his appearance by shaving his beard, and that it would be difficult to consistently measure half-inch beards. The magistrate ultimately deferred to the judgment of the prison officials, relying on Eighth Circuit precedent, and recommended that Holt's motion be denied. The District Court adopted the magistrate's recommendations, and the Eighth Circuit affirmed. [2] :8–11

Holt then filed a pro se petition for a writ of certiorari and a request to proceed in forma pauperis . [3] On March 3, 2014, the Supreme Court agreed to hear the case. [4]

Supreme Court decision

The majority opinion written by Alito said that RLUIPA does not require a prison to grant religious exemptions simply because a prisoner asks or because other prisons do. [5] However, Arkansas officials offered no evidence that a short beard presented security risks or could serve as a hiding place for contraband, as the officials argued. Arkansas had not overcome the high hurdles set by the law: that policymakers may not burden a person’s exercise of religion unless they can show a compelling governmental interest and that the policy was the least-restrictive means of achieving that goal. In a concurrence, Justice Ginsburg, contrasting the case with Burwell v. Hobby Lobby , said accommodating Holt’s request "would not detrimentally affect others who do not share petitioner's belief." [6] In a separate concurrence, Justice Sotomayor disagreed with the majority's application of RLUIPA, but did agree that Arkansas officials did not adequately respond to Holt's request to keep a beard. [5]

See also

Related Research Articles

<span class="mw-page-title-main">Arkansas Department of Corrections</span>

The Arkansas Department of Corrections (DOC), formerly the Arkansas Department of Correction, is the state law enforcement agency that oversees inmates and operates state prisons within the U.S. state of Arkansas. DOC consists of two divisions, the Arkansas Division of Corrections (ADC) and the Arkansas Division of Community Corrections (DCC), as well as the Arkansas Correctional School District. ADC is responsible for housing and rehabilitating people convicted of crimes by the courts of Arkansas. ADC maintains 20 prison facilities for inmates in 12 counties. DCC is responsible for adult parole and probation and offender reentry.

Holt v. Sarver was a court decision that was the first in a series of American common law cases that have found entire state prison systems in violation of prisoners' constitutional rights by inflicting cruel and unusual punishment.

<span class="mw-page-title-main">Religious Land Use and Institutionalized Persons Act</span>

The Religious Land Use and Institutionalized Persons Act (RLUIPA), Pub. L. 106–274 (text)(PDF), codified as 42 U.S.C. § 2000cc et seq., is a United States federal law that prohibits the imposition of burdens on the ability of prisoners to worship as they please and gives churches and other religious institutions a way to avoid zoning law restrictions on their property use. It also defines the term "religious exercise" to include "any exercise of religion, whether or not compelled by, or central to, a system of religious belief." RLUIPA was enacted by the United States Congress in 2000 to correct the problems of the Religious Freedom Restoration Act (RFRA) of 1993. The act was passed in both the House of Representatives and the Senate by unanimous consent in voice votes, meaning that no objection was raised to its passage, so no written vote was taken. The S. 2869 legislation was enacted into law by the 42nd President of the United States Bill Clinton on September 22, 2000.

Becket Law, formerly the Becket Fund for Religious Liberty, is a non-profit public interest law firm based in Washington, D.C., that describes its mission as "defending the freedom of religion of people of all faiths". Becket promotes accommodationism and is active in the judicial system, the media, and in education.

Inmates incarcerated in the United States penal system practice a variety of religions. Their basic constitutional right to worship has been reinforced by decades of court decisions and more recently by the Religious Land Use and Institutionalized Persons Act. However, several of these court rulings have also set limitations on these rights when prisoner demands are seen to impede prison safety and function.

Beard v. Banks, 548 U.S. 521 (2006), was a case decided by the United States Supreme Court in which the petitioner, Ronald Banks, challenged the constitutionality of the Pennsylvania Department of Corrections policy of denying access to written material such as newspapers and magazines, to violent inmates, on the grounds that the policy was a violation of his First Amendment rights, including freedom of speech.

Cooper v. Pate, 378 U.S. 546 (1964), was a U.S. Supreme Court case in which the court ruled for the first time that state prison inmates have the standing to sue in federal court to address their grievances under the Civil Rights Act of 1871. This case followed Jones v. Cunningham (1963) allowing prison inmates to employ a writ of habeas corpus to challenge the legality of their sentencing and the conditions of their imprisonment.

Cruz v. Beto, 405 U.S. 319 (1972), was a United States Supreme Court case in which the court upheld a Free Exercise claim based on the allegations that the state of Texas had discriminated against a Buddhist prisoner by "denying him a reasonable opportunity to pursue his Buddhist faith comparable to that offered other prisoners adhering to conventional religious precepts."

Jailhouse Jesus is the colloquial term for an observed psychological phenomenon of new inmates to 'find religion' during their incarceration. Whether it comes from a genuine desire to "repent", an appeal to authority, or other factors is a subject for debate.

Farmer v. Brennan, 511 U.S. 825 (1994), was a case in which the Supreme Court of the United States ruled that a prison official's "deliberate indifference" to a substantial risk of serious harm to an inmate violates the cruel and unusual punishment clause of the Eighth Amendment. Farmer built on two previous Supreme Court decisions addressing prison conditions, Estelle v. Gamble and Wilson v. Seiter. The decision marked the first time the Supreme Court directly addressed sexual assault in prisons.

Conversion to Islam in U.S. prisons refers to the contemporary high rate of conversion to Islam in American prisons, for which there are a number of factors. It is the fastest growing religion in U.S. prisons, where the population is 18 percent Muslim ; 80 percent of all prison religious conversions are to Islam.

United States v. Georgia, 546 U.S. 151 (2006), was a United States Supreme Court case in which the Court decided that the protection of Americans with Disabilities Act of 1990 (ADA), passed by the U.S. Congress, extends to persons held in a state prison and protects prison inmates from discrimination on the basis of disability by prison personnel. Specifically, the court held that Title II of the Americans with Disabilities Act of 1990, 42 U.S.C. §§ 1213112165., is a proper use of Congressional power under the Fourteenth Amendment, Section 5, making it applicable to prison system officials.

<span class="mw-page-title-main">Tucker Unit</span>

The Tucker Unit is a prison in Dudley Lake Township, unincorporated Jefferson County, Arkansas, 25 miles (40 km) northeast of Pine Bluff. It is operated by the Arkansas Department of Correction (ADC). Tucker is one of the state of Arkansas's "parent units" for male prisoners; it serves as one of several units of initial assignment for processed male prisoners. It is in proximity to, but not within, the Tucker census-designated place.

<span class="mw-page-title-main">Facial hair in the military</span>

Facial hair in the military has been at various times common, prohibited, or an integral part of the uniform.

Miller v. Alabama, 567 U.S. 460 (2012), was a United States Supreme Court case in which the Court held that mandatory sentences of life without the possibility of parole are unconstitutional for juvenile offenders. The ruling applied even to those persons who had committed murder as a juvenile, extending beyond Graham v. Florida (2010), which had ruled juvenile life without parole sentences unconstitutional for crimes excluding murder.

Zubik v. Burwell, 578 U.S. ___ (2016), was a case before the United States Supreme Court on whether religious institutions other than churches should be exempt from the contraceptive mandate, a regulation adopted by the United States Department of Health and Human Services (HHS) under the Affordable Care Act (ACA) that requires non-church employers to cover certain contraceptives for their female employees. Churches are already exempt under those regulations. On May 16, 2016, the Supreme Court vacated the Court of Appeals ruling in Zubik v. Burwell and the six cases it had consolidated under that title and returned them to their respective courts of appeals for reconsideration.

In the United States of America, Prisoner Law refers to litigation that determines the freedoms that a prisoner either holds or loses when they are incarcerated. This includes the end of the Hands- Off Doctrine and the ability to be protected by the First, Fourth, Eighth, and Fourteenth Amendments. Furthermore, prisoner laws regulate the ways in which individuals experience privacy in a prison setting. Important case laws have arisen through time that have either hindered or protected prisoners from certain rights. Some include the Hudson v. Palmer case which held that prisoners were not protected against searches and seizures of their prison cells and Wolff v. McDonnell that stated that prisoners shall remain entitled to some of their constitutional rights even after being incarcerated.

Hutto v. Finney, 437 U.S. 678 (1978), is a landmark Supreme Court case against the Arkansas Department of Correction. The litigation lasted almost a decade, from 1969 through 1978. It was the first successful lawsuit filed by an inmate against a correctional institution. The case also clarified the Arkansas prison system's unacceptable punitive measures. Hutto v. Finney was a certiorari to the United States Court of Appeals for the Eighth Circuit.

Dunn v. Ray, 586 U.S. ___ (2019), was a February 2019 United States Supreme Court case related to religious freedom. The case attracted media attention in early February 2019. Defendant Domineque Hakim Marcelle Ray, an Alabama death row inmate scheduled for execution on February 7, 2019, argued that he had the right to have a Muslim imam present in the execution chamber, instead of the Christian chaplain mandated by Alabama's execution protocol. Ray received a stay from the 11th Circuit Court of Appeals the day before his execution, but Alabama moved for the Supreme Court to vacate the stay of execution. The Supreme Court vacated the stay and Ray was executed on his scheduled date. He was one of 22 people executed in the United States in 2019.

References

  1. Sherman, Mark (January 20, 2015). "Supreme Court rules for bearded Muslim inmate". Associated Press. Archived from the original on January 21, 2015. Retrieved January 20, 2015.
  2. 1 2 3 "Brief for the Petitioner" (PDF). May 22, 2014. Retrieved November 30, 2014.
  3. "Petition for Writ of Certiorari" (PDF). September 27, 2013. Retrieved November 30, 2014.
  4. "Docket No. 13-6827, Gregory Houston Holt, aka Abdul Maalik Muhammad, Petitioner v. Ray Hobbs, Director, Arkansas Department of Correction, et al" . Retrieved November 30, 2014.
  5. 1 2 Holt v. Hobbs,No. 13-6827 , 574 U.S. 352 (2015).
  6. "Religious Liberty: Of beards and brevity". The Economist. January 21, 2015. Retrieved January 30, 2015.

Further reading