Holt v. Hobbs

Top 10 Case
Becket Role:


Decision Date:
January 20, 2015
Deciding Court:
U.S. Supreme Court


Case Summary

Sixteen years ago, Congress found that government bureaucrats routinely trample on religious liberty in prison. As the joint statement of Senators Hatch (R-UT) and Kennedy (D-MA) put it: “Whether from indifference, ignorance, bigotry, or lack of resources, some institutions restrict religious liberty in egregious and unnecessary ways.”  For example:

  • Many prisons barred Jewish inmates from wearing yarmulkes, denied Catholics access to the sacraments of communion and confession, and shut down Evangelical Bible studies.
  • Many prisons banned religious diets such as kosher food.
  • Prisons often confiscated and destroyed sacred texts, such as the Bible, the Koran, the Bhagavad Gita, and various prayer books.
  • Prisons often banned religious objects, such as rosaries, prayer shawls, and yarmulkes.
  • One prison prohibited various religious holidays, restricting prisoners’ ability to fast, pray, and worship God on special occasions.
  • In one extreme instance, prison officials violated the seal of the confessional by bugging inmates’ confessions to their priests.
  • See examples of why protecting religious expression of prisoners is important:

In response to these and many other displays of religious suppression, an overwhelmingly bipartisan Congress enacted a landmark civil rights statute, which was signed by President Clinton in 2000: the Religious Land Use and Institutionalized Persons Act (RLUIPA).

RLUIPA embodies a very simple principle: Prison officials should not impose egregious and unnecessary restrictions on religious liberty. Of course, prisoners lose many of their physical rights when they enter prison, but they cannot be forced to surrender peaceful expressions of their humanity due to the arbitrary whims of prison officials. Just as the Constitution prevents dehumanizing forms of cruel and unusual punishment, RLUIPA prevents stubborn bureaucrats from stripping inmates of human dignity by denying them the ability to seek God.

Despite RLUIPA’s protections, some inmates still face persecution for peaceful displays of religious devotion. In the case of Holt v. Hobbs, Abdul Muhammad, an Arkansas inmate, has been denied the ability to grow the ½ inch beard his Muslim faith commands—even though Arkansas already allows inmates to grow beards for medical reasons, and Mr. Muhammad’s beard would be permissible in 44 state and federal prison systems across the country.

On June 28, 2011, Mr. Muhammad, representing himself, filed a lawsuit seeking the ability to wear a half-inch beard in accordance with his faith. Mr. Muhammad lost in federal trial court and in the Eighth Circuit Court of Appeals in St. Louis. He then submitted a handwritten petition for an injunction to the Supreme Court. Justice Alito read the petition and sent it to the entire Court for decision, and the Court granted the petition. On March 3, 2014, the Supreme Court said that it would hear his appeal in full. Oral argument took place October 7, 2014. Mr. Muhammad is now represented by Professor Douglas Laycock of the University of Virginia School of Law and Becket.

On January 20, 2015, the Supreme Court ruled unanimously in favor of Mr. Muhammad. The Court held that Mr. Muhammad had clearly shown a substantial burden on his religious exercise because Arkansas had put him to the choice of violating his beliefs or suffering disciplinary sanctions. The Court rejected Arkansas’s defenses, pointing out that because so many other states were able to accommodate beard-wearing, Arkansas had to explain why its situation was different.

On June 4, 2015, a federal district court issued a permanent injunction against the state. Arkansas agreed to the injunction, which requires the state to allow a prisoner to grow a religiously-mandated beard.

Case Information

Becket Role:
Case Start Date:
June 28, 2011
Deciding Court:
U.S. Supreme Court
Original Court:
U.S. District Court for the Eastern District of Arkansas
Supreme Court Status:
Practice Area(s):