Holt v. Payne
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Case Snapshot
In 2011, Gregory Holt, an inmate in an Arkansas state prison, sued for his right to grow a beard in accordance with his Muslim faith. Defended by Becket and Professor Douglas Laycock of the University of Virginia Law School, Holt won his case unanimously at the Supreme Court under the Religious Land Use and Institutionalized Persons Act (RLUIPA). Years later, however, Holt—who also goes by his religious name, Abdul Maalik Muhammad—is back in court alongside fellow Muslim inmates Rodney Martin and Wayde Earl Stewart after the Arkansas Department of Corrections refused to accommodate their right to wear a religiously required cap and attend Muslim prayer services.
Status
On July 18, 2022, Becket filed a friend-of-the-court brief at the U.S. Court of Appeals for the Eighth Circuit, arguing for Mr. Muhammad’s freedom to religious expression protected by RLUIPA. On November 2, 2023, the Eighth Circuit reaffirmed that inmates enjoy the full religious liberty rights described by the U.S. Supreme Court in Holt v. Hobbs, and held that the District Court was wrong to rule against Mr. Muhammad and the other Muslim inmates who sued alongside him.
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Case Summary
Muslim prisoner secures victory at the High Court
Abdul Maalik Muhammad is an inmate in Arkansas state prison and a devout Muslim. In 2011, Muhammad sued the Arkansas Department of Corrections when he was denied his ability to maintain a half-inch beard in accordance with his Muslim beliefs. After losing his case in the lower court, Becket and Professor Douglas Laycock of University of Virginia Law School stepped in to represent him at the U.S. Supreme Court. In January 2015, the U.S. Supreme Court ruled 9-0 in Muhammad’s favor, agreeing with Becket that denying his request to grow a religious beard violated the Religious Land Use and Institutionalized Persons Act (RLUIPA), a Congressional act passed with bipartisan support in 2000.
Arkansas continues its campaign against religious inmates
After his victory at the Supreme Court, the Arkansas Department of Corrections then tried to bar Muhammad from wearing a religiously required cap (kufi) and attending Friday prayer services. Though his prison held up to five different services for different Christian denominations, it refused to hold more than one Quran-based Friday prayer service each week. This forced Muslims like Muhammad and his fellow plaintiffs Rodney Martin and Wayde Earl Stewart to pray alongside adherents of Nation of Islam and Nation of Gods and Earth, who they believe do not share their Islamic beliefs. Muhammad believes that for their Friday prayer service to be valid, it must be led by and limited to Muslim believers. The district court ruled that Muhammad and his fellow Muslim inmates were not sincere in their beliefs because some had occasionally attended mixed prayer services, while others chose to boycott and didn’t attend any services that violated their faith.
Religious believers are protected behind bars
Becket filed a friend-of-the-court at the Eighth Circuit brief identifying at least 20 other prison systems that allow inmates like Muhammad to wear their kufi throughout the prison and asking the Court to hold Arkansas to the rigorous standard the Supreme Court set last time around. Although prisoners lose many of their rights when they are imprisoned, they should not be forced to sacrifice their commitment to their faith.
On November 2, 2023, the Eighth Circuit ruled in favor of Muhammad and his fellow plaintiffs, rebuking the district court for wrongly dismissing many of the plaintiffs’ arguments. The Eighth Circuit reaffirmed the religious liberty standards set by the U.S. Supreme Court and upheld by many other courts of appeals nationwide, and sent the case back down so that the court could apply the correct legal standard.
Importance to religious liberty:
- Individual freedom: Individual religious freedom encompasses more than just thought or contemplation—it involves action. Individuals must be free to follow their religious convictions into practice, including when they are incarcerated.
- RLUIPA: Like the Religious Freedom Restoration Act (RFRA), the Religious Land Use and Institutionalized Persons Act (RLUIPA) was passed with bipartisan support. RLUIPA ensures religious liberty in two areas where it is most vulnerable: land use and prisons