__ U.S. __ (2015), 13-6827, Holt v. Hobbs

Docket Nº13-6827
Citation__ U.S. __, 135 S.Ct. 853, 190 L.Ed.2d 747, 83 U.S.L.W. 4065, 25 Fla.L.Weekly Fed. S 43
Opinion JudgeAlito, Justice.
Party NameGREGORY HOUSTON HOLT, aka ABDUL MAALIK MUHAMMAD, Petitioner v. RAY HOBBS, DIRECTOR, ARKANSAS DEPARTMENT OF CORRECTION, et al
AttorneyDouglas Laycock argued the cause for petitioner. Anthony A. Yang argued the cause for the United States, as amicus curiae, by special leave of court. David A. Curran argued the cause for respondents.
Judge PanelAlito, J., delivered the opinion for a unanimous Court. Ginsburg, J., filed a concurring opinion, in which Sotomayor, J., joined. Sotomayor, J., filed a concurring opinion. Justice Ginsburg, with whom Justice Sotomayor joins, concurring. Justice Sotomayor, concurring.
Case DateJanuary 20, 2015
CourtUnited States Supreme Court

Page __

__ U.S. __ (2015)

135 S.Ct. 853, 190 L.Ed.2d 747, 83 U.S.L.W. 4065, 25 Fla.L.Weekly Fed. S 43

GREGORY HOUSTON HOLT, aka ABDUL MAALIK MUHAMMAD, Petitioner

v.

RAY HOBBS, DIRECTOR, ARKANSAS DEPARTMENT OF CORRECTION, et al

No. 13-6827

United States Supreme Court

January 20, 2015

[135 S.Ct. 855] Argued: October 7, 2014.

ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT

Reversed and remanded.

DECISION:

Prison's general beard prohibition held to violate Religious Land Use and Institutionalized Persons Act of 2000 provision (42 U.S.C.S. § 2000cc-1(a)) by substantially burdening inmate's sincere belief that beard was required by his religion.

LAWYERS' EDITION HEADNOTES:

[190 L.Ed.2d 748] CIVIL RIGHTS § 46

INSTITUTIONALIZED PERSON -- RELIGION

Headnote:[1]

The Religious Land Use and Institutionalized Persons Act of 2000, 42 U.S.C.S. § 2000cc et seq., prohibits a state or local government from taking any action that substantially burdens the religious exercise of an institutionalized person unless the government demonstrates that the action constitutes the least restrictive means of furthering a compelling governmental interest.

CIVIL RIGHTS § 46

INSTITUTIONALIZED PERSON -- RELIGION

Headnote:[2]

See 42 U.S.C.S. § 2000cc-1(a), which prohibits a substantial governmental burden on the religious exercise of an institutionalized person, even if the burden results from a general rule, unless the government demonstrates that the burden is (1) in furtherance of a compelling governmental interest; and (2) the least restrictive means of furthering that interest.

CIVIL RIGHTS § 46

INSTITUTIONALIZED PERSONS -- RELIGION

Headnote:[3]

Several provisions of the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), 42 U.S.C.S. § 2000cc et seq., underscore its expansive protection for religious liberty. Congress define " religious exercise" capaciously to include any exercise of religion, whether or not compelled by, or central to, a system of religious belief. 42 U.S.C.S. § 2000cc-5(7)(A). Congress mandates that this concept shall be construed in favor of a broad protection of religious exercise, to the maximum extent permitted by the terms of the chapter and the Federal Constitution. 42 U.S.C.S. § 2000cc-3(g). RLUIPA may require a government to incur expenses in its own operations to avoid imposing a substantial burden on religious exercise. § 2000cc-3(c).

CIVIL RIGHTS § 46EVIDENCE § 383

INSTITUTIONALIZED PERSONS -- RELIGION -- BURDEN OF PROOF

Headnote:[4]

Under the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), 42 U.S.C.S. § 2000cc et seq., a petitioner bears the initial burden of proving that a policy implicates his religious exercise. RLUIPA protects any exercise of religion, whether or not compelled by, or central to, a system of religious belief, 42 U.S.C.S. § 2000cc-5(7)(A), but, of course, a petitioner's request for an accommodation must be sincerely based on a religious belief and not some other motivation.

CIVIL RIGHTS § 46CONSTITUTIONAL LAW § 980

INSTITUTIONALIZED PERSONS -- RELIGIOUS BELIEFS

Headnote:[5]

The protection of the Religious Land Use and Institutionalized Persons Act of 2000, 42 U.S.C.S. § 2000cc et seq., no less than the guarantee of the free exercise clause, is not limited to beliefs which are shared by all of the members of a religious sect.

CIVIL RIGHTS § 46

INSTITUTIONALIZED PERSONS -- EXERCISE OF RELIGION -- JUDICIAL REVIEW

Headnote:[6]

The Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), 42 U.S.C.S. § 2000cc et seq., contemplates a focused inquiry and requires the government to demonstrate that the compelling interest test is satisfied through application of the challenged law to the person--the particular claimant whose sincere exercise of religion is being substantially burdened. 42 U.S.C.S. § 2000bb-1(b). RLUIPA requires courts to scrutinize the asserted harm of granting specific exemptions to particular religious claimants and to look to the marginal interest in enforcing the challenged government action in that particular context.

[190 L.Ed.2d 749] CIVIL RIGHTS § 46

INSTITUTIONALIZED PERSONS -- RELIGION -- RESPECTING EXPERTISE

Headnote:[7]

The Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), 42 U.S.C.S. § 2000cc et seq., makes clear that it is the obligation of the courts to consider whether exceptions are required under the test set forth by Congress. That test requires the government not merely to explain why it denied the exemption but to prove that denying the exemption is the least restrictive means of furthering a compelling governmental interest. Prison officials are experts in running prisons and evaluating the likely effects of altering prison rules, and courts should respect that expertise. But that respect does not justify the abdication of the responsibility, conferred by Congress, to apply RLUIPA's rigorous standard.

EVIDENCE § 383

INSTITUTIONALIZED PERSONS -- RELIGION -- STANDARD OF PROOF

Headnote:[8]

The least-restrictive-means standard of the Religious Land Use and Institutionalized Persons Act of 2000, 42 U.S.C.S. § 2000cc et seq., is exceptionally demanding, and it requires the government to show that it lacks other means of achieving its desired goal without imposing a substantial burden on the exercise of religion by the objecting party. If a less restrictive means is available for the government to achieve its goals, the government must use it.

SYLLABUS

[135 S.Ct. 856] [190 L.Ed.2d 750] Section 3 of the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA) provides that " [n]o government shall impose a substantial burden on the religious exercise" of an institutionalized person unless the government demonstrates that the burden " is the least restrictive means of furthering [a] compelling governmental interest." 42 U.S.C. § 2000cc-1(a).

Petitioner is an Arkansas inmate and devout Muslim who wishes to grow a 1\2-inch beard in accordance with his religious beliefs. Respondent Arkansas Department of Correction (Department) prohibits its prisoners from growing beards, with the single exception that inmates with diagnosed skin conditions may grow 1/4-inch [135 S.Ct. 857] beards. Petitioner sought an exemption on religious grounds and, although he believes that his faith requires him not to trim his beard at all, he proposed a compromise under which he would be allowed to maintain a 1\2-inch beard. Prison officials denied his request, and petitioner sued in Federal District Court. At an evidentiary hearing before a Magistrate Judge, Department witnesses testified that beards compromised prison safety because they could be used to hide contraband and because an inmate could quickly shave his beard to disguise his identity. The Magistrate Judge recommended dismissing petitioner's complaint, emphasizing that prison officials are entitled to deference on security matters and that the prison permitted petitioner to exercise his religion in other ways. The District Court adopted the recommendation in full, and the Eighth Circuit affirmed, holding that the Department had satisfied its burden of showing that the grooming policy was the least restrictive means of furthering its compelling security interests, and reiterating that courts should defer to prison officials on matters of security.

Held: The Department's grooming policy violates RLUIPA insofar as it prevents petitioner from growing a 1\2-inch beard in accordance with his religious beliefs. Pp. ___ - ___, 190 L.Ed.2d, at 755-761.

(a) Under RLUIPA, the challenging party bears the initial burden of proving that his religious exercise is grounded in a sincerely held religious belief, see Burwell v. Hobby Lobby Stores, Inc., 573 U.S. ___, ___, n. 28, 134 S.Ct. 2751, 189 L.Ed.2d 675, 702, and that the government's action substantially burdens his religious exercise. Here, petitioner's sincerity is not in dispute, and he easily satisfies the second obligation. The Department's policy forces him to choose between " engag[ing] in conduct that seriously violates [his] religious belie[f]," id., at ___, 134 S.Ct. 2751, 189 L.Ed.2d 675, 704 or contravening the grooming policy and risking disciplinary action. In reaching the opposite conclusion, the District Court misunderstood the analysis that RLUIPA demands. First, the District Court erred by concluding that the grooming policy did not substantially burden petitioner's religious exercise because he could practice his religion in other ways. Second, the District Court erroneously suggested that the burden on petitioner's religious exercise was slight because petitioner testified that his religion would " credit" him for attempting to follow his religious beliefs, even if that attempt proved unsuccessful. RLUIPA, however, applies to religious exercise regardless of whether it is " compelled." § 2000cc-5(7)(A). [190 L.Ed.2d 751] Finally, the District Court improperly relied on petitioner's testimony that not all Muslims believe that men must grow beards. Even if petitioner's belief were idiosyncratic, RLUIPA's guarantees are " not limited to beliefs which are shared by all of the members of a religious sect." Thomas

v. Review Bd. of Indiana Employment Security Div., 450 U.S. 707, 715-716, 101 S.Ct. 1425, 67 L.Ed.2d 624. Pp. ___ - ___, 190 L.Ed.2d, at 755-756.

(b) Once the challenging party satisfies his burden, the burden shifts to the government to show that substantially burdening the religious exercise of the " particular claimant" is " the least restrictive means of furthering [a] compelling governmental interest." Hobby Lobby, supra, at ___, 134 S.Ct. 2751, 189 L.Ed.2d 675, 708; § 2000cc-1(a). The Department fails to show that enforcing its beard prohibition against petitioner furthers its compelling interests in preventing prisoners from hiding contraband and...

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610 practice notes
  • Federal Law Protections for Religious Liberty
    • United States
    • Federal Register October 26, 2017
    • October 26, 2017
    ...expenses in its own operations to avoid imposing a substantial burden on religious exercise.'' Id. Sec. 2000cc-3(c); cf. Holt v. Hobbs, 135 S. Ct. 853, 860, 864-65 With respect to land use in particular, RLUIPA also requires that government not ``treat a religious assembly or institution on......
  • 114 A.3d 900 (Pa.Cmwlth. 2015), 365 C.D. 2014, Mallory v. Stanitis
    • United States
    • Pennsylvania Commonwealth Court of Pennsylvania
    • May 5, 2015
    ...held religious belief (iii) that is substantially burdened by a prison policy. 42 U.S.C. § 2000cc-1(a); Holt v. Hobbs, __ U.S. __, 135 S.Ct. 853, 860, 190 L.Ed.2d 747 (2015). Once the inmate makes this prima facie showing, the burden shifts to the government to show that its refusal to acco......
  • 231 A.3d 326 (Conn.App. 2020), AC 42550, Gawlik v. Semple
    • United States
    • Connecticut Appellate Court of Connecticut
    • April 28, 2020
    ...(2) the government's action or policy "substantially burden[s] that exercise. ..." Holt v. Hobbs, 574 U.S. 352, 361, 135 S.Ct. 853, 190 L.Ed.2d 747 (2015). If the plaintiff carries this threshold burden, the burden shifts to the government to show that the ......
  • 443 F.Supp.3d 612 (D.Md. 2020), C. A. ELH-19-0327, Pevia v. Hogan
    • United States
    • Federal Cases United States District Courts 4th Circuit United States District Court (Maryland)
    • March 3, 2020
    ...§ 2000bb et seq., `in order to provide very broad protection for religious liberty.'" Holt v. Hobbs, 574 U.S. 352, 356, 135 S.Ct. 853, 859, 190 L.Ed.2d 747 (2015) (quoting Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682, 693, 134 S.Ct. 2751, 189 L.Ed.2d 675 (......
  • Request a trial to view additional results
577 cases
  • 114 A.3d 900 (Pa.Cmwlth. 2015), 365 C.D. 2014, Mallory v. Stanitis
    • United States
    • Pennsylvania Commonwealth Court of Pennsylvania
    • May 5, 2015
    ...held religious belief (iii) that is substantially burdened by a prison policy. 42 U.S.C. § 2000cc-1(a); Holt v. Hobbs, __ U.S. __, 135 S.Ct. 853, 860, 190 L.Ed.2d 747 (2015). Once the inmate makes this prima facie showing, the burden shifts to the government to show that its refusal to acco......
  • 231 A.3d 326 (Conn.App. 2020), AC 42550, Gawlik v. Semple
    • United States
    • Connecticut Appellate Court of Connecticut
    • April 28, 2020
    ...(2) the government's action or policy "substantially burden[s] that exercise. ..." Holt v. Hobbs, 574 U.S. 352, 361, 135 S.Ct. 853, 190 L.Ed.2d 747 (2015). If the plaintiff carries this threshold burden, the burden shifts to the government to show that the ......
  • 443 F.Supp.3d 612 (D.Md. 2020), C. A. ELH-19-0327, Pevia v. Hogan
    • United States
    • Federal Cases United States District Courts 4th Circuit United States District Court (Maryland)
    • March 3, 2020
    ...§ 2000bb et seq., `in order to provide very broad protection for religious liberty.'" Holt v. Hobbs, 574 U.S. 352, 356, 135 S.Ct. 853, 859, 190 L.Ed.2d 747 (2015) (quoting Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682, 693, 134 S.Ct. 2751, 189 L.Ed.2d 675 (......
  • 447 F.Supp.3d 466 (E.D.N.C. 2020), 7:18-CV-86-FL, O'Connell v. City of New Bern
    • United States
    • Federal Cases United States District Courts 4th Circuit Eastern District of North Carolina
    • March 10, 2020
    ...the Religious Freedom Restoration Act of 1993 ("RFRA"), 42 U.S.C. § 2000bb et seq. Holt v. Hobbs, 574 U.S. 352, 356, 135 S.Ct. 853, 190 L.Ed.2d 747 (2015). RFRA places limits on the government's ability to substantially burden exercise of religion "ev......
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4 firm's commentaries
27 books & journal articles
  • Criminal justice and the 2014-2015 United States Supreme Court term.
    • United States
    • South Dakota Law Review Vol. 61 Nbr. 2, June - June 2016
    • June 22, 2016
    ...officer that gives rise to reasonable suspicion can justify a traffic stop under the Fourth Amendment). (9.) See generally Holt v. Hobbs, 135 S. Ct. 853 (2015) (upholding a prisoner's right to grow short beards in accordance with religious beliefs); Ohio v. Clark, 135 S. Ct. 2173 (2015) (ad......
  • PRECEDENT AND PRECLUSION.
    • United States
    • Notre Dame Law Review Vol. 93 Nbr. 2, December 2017
    • December 1, 2017
    ...(a). (144) See Gonzales v. O Centra Espirita Beneficente Uniao do Vegetal, 546 U.S. 418, 430-31, 436 (2006); see also Holt v. Hobbs, 135 S. Ct. 853, 863-64 (2015). The Court has also made clear that the RLUIPA test applies the same standards as those developed in the context of the Religiou......
  • Ruiz-Diaz v. United States: RFRA, substantial burden, and the Ninth Circuit's causation-nexus requirement - a wrinkle or a roadblock for future immigration-related religious freedom challenges?
    • United States
    • Albany Law Review Vol. 79 Nbr. 2, December 2015
    • December 22, 2015
    ...(100) Id. at 2779 (citing Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal, 546 U.S. 418, 430-31 (2006)). (101) Holt v. Hobbs, 135 S. Ct. 853 (2015). (102) Id. at 859. (103) Hosanna-Tabor Evangelical Lutheran Church & Sch. v. EEOC, 132 S. Ct. 694, 701, 710 (2012). (104) Hobbs,......
  • Conscience wars: complicity-based conscience claims in religion and politics.
    • United States
    • Yale Law Journal Vol. 124 Nbr. 7, May - May 2015
    • May 1, 2015
    ...(quoting Conestoga Wood Specialties Corp. v. Sec'y of U.S. Dep't of Health & Human Servs., 724 F.3d 377, 382 (3d Cir. 2013)). (27.) 135 S. Ct. 853 (2015). (28.) Holt asserted his claim under the Religious Land Use and Institutionalized Persons Act (RLUIPA), a statute that shares signifi......
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2 provisions
  • Federal Law Protections for Religious Liberty
    • United States
    • Federal Register October 26, 2017
    • October 26, 2017
    ...expenses in its own operations to avoid imposing a substantial burden on religious exercise.'' Id. Sec. 2000cc-3(c); cf. Holt v. Hobbs, 135 S. Ct. 853, 860, 864-65 With respect to land use in particular, RLUIPA also requires that government not ``treat a religious assembly or institution on......
  • Implementing Legal Requirements Regarding the Equal Opportunity Clause's Religious Exemption
    • United States
    • Federal Contract Compliance Programs Office
    • Invalid date
    ...each owned and controlled by a single family, and no one has disputed the sincerity of their religious beliefs.''); Holt v. Hobbs, 135 S. Ct. 853, 862 (2015) (``Here, the religious exercise at issue is the growing of a beard, which petitioner believes is a dictate of his religious faith, an......