Lower Court Holding in Holt v. Hobbs
Decision of the Eighth Circuit U.S. Court of Appeals
In this action challenging the Arkansas Department of Correction (ADC) grooming policy under the Religious Land Use and Institutionalized Persons Act (RLUIPA), inmate Gregory Holt (also known as Abdul Maalik Muhammad) appeals the district court’s order dismissing his action after an evidentiary hearing. In his complaint and motion for a preliminary injunction and temporary restraining order, Holt asserted that one of his fundamentalist Muslim beliefs was that he must grow a beard, but defendants substantially burdened his ability to practice his religion by enforcing ADC’s grooming policy, which allowed trimmed mustaches but otherwise no facial hair, with quarter-inch beards permitted…
