Holt v. Hobbs

Posted: February 22, 2015 by beguide in case summaries, Religious Freedom


WHAT HAPPENED: Holt is a criminal defendant who is incarcerated for a host of violent, extreme crimes. During Holt’s stay in federal prison, Holt requested the right to grow a one-half-inch beard as part of a necessary practice in his religion. Hobbs is, for lack of better qualifier, a representative of the prison that denied Holt the right to grow his beard. The prison has a grooming policy that prohibits inmates from growing facial hair, which is based on prison safety.

WHY IS THIS BEFORE THE SUPREME COURT: This case revisits the a different form of the Religious Freedom and Restoration Act covered in the Hobby Lobby case, which is a federal statute that protects citizens from government action that infringes upon private religious beliefs. The Religious Land Use and Institutionalized Persons Act of 2000 prevents government actors from unfairly inhibiting an inmate’s exercise of religion, unless the government is able to show a compelling purpose in favor of the law and that the law is the least restrictive means of interfering with the inmate’s religion. Hobbs was therefore required to show that the prison policy preventing Holt from growing a beard had a compelling reason that was the least restrictive means of achieving that goal.

WHAT WAS THE RULING: The Court ruled 9-0 in favor of Holt and struck down the prison grooming policy as it applied in this case.   Justice Alito wrote the majority opinion which stated primarily that preventing inmates from growing short beards for sincerely held religious beliefs was the least restrictive means of achieving prison safety. The Court furthermore held that providing different religious accommodations to Holt did not excuse the prison’s ban on facial hair. Justice Ginsberg, she of the blistering dissent in Hobby Lobby, stated that Hobby Lobby had nothing to do with this case because Holt’s request only affected his own beliefs, and not the beliefs of others.


THE GOOD GUYS WON IF YOU: appreciate the irony of the Hobby Lobby decision, which is generally considered a case favoring right-wing Christian beliefs, allowing a Muslim extremist to grow a beard in jail.

THE BAD GUYS WON IF YOU: were hoping that the religious accommodations in Hobby Lobby were restricted to just that case.

WHO WAS RIGHT: This was a bit of a slam dunk in favor of Holt, as both Brett and Nazim believed that Holt was going to win. Brownie points go to the podcast for addressing the Hobby Lobby connection which the majority touched on and Ginsberg downplayed in her concurring opinion.

  1. […] by listeners and update previous cases that have since been decided.  The topics this week include Holt v. Hobbs, smart phone technology, why DUI checkpoints are acceptable under the 4th amendment, and the […]


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