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Holt v. Hobbs

United States Supreme Court

January 20, 2015

GREGORY HOUSTON HOLT, aka ABDUL MAALIK MUHAMMAD, Petitioner
v.
RAY HOBBS, DIRECTOR, ARKANSAS DEPARTMENT OF CORRECTION, et al

[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. ยง 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 ...


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