Holt v. Hobbs
There is much more to the First Amendment than the Free Speech Clause. In Holt v. Hobbs, the Court invoked the First Amendment’s religious protections in ruling on whether prison officials violated the Religious Land Use and Institutionalized Persons Act (“RLUIPA”) by prohibiting a Muslim inmate named Gregory Holt from growing a half-inch beard when other inmates received medical exemptions allowing them to grow a quarter-inch beard. [Read our Preview here.] The RLUIPA extends the Court’s strict scrutiny standard to religious practices whenever a government actor attempts to impose a “substantial burden” on a religious practice regardless of whether such practices are compelled by a religious belief. Holt’s Muslim faith required him to grow a beard; but, the prison denied his request to grow a half-inch beard, citing security concerns. Lower courts sided with the prison; but a unanimous Supreme Court reversed them and remanded the case for further proceedings consistent with its holding that the prison’s grooming policy violated RLUIPA because it prevents Holt from growing a one-half inch beard as required by his religious beliefs.