Holt a/k/a/ Muhammad v Hobbs

Statutory right to practice religion – Substantial burden on – Arkansas Department of Correction (‘ADC') grooming policy requiring inmates to be clean-shaven other than moustaches and quarter-inch beards for diagnosed dermatological problems – Muslim inmate challenging grooming policy under federal Religious Land Use and Institutionalized Persons Act, asserting fundamentalist belief requiring he grow a beard – Inmate seeking permission to maintain half-inch beard as compromise position – District court granting inmate temporary injunctive relief – Hearing producing evidence of prison officials’ particular interest in prison security and extensive efforts to accommodate inmate’s religious practices – District court revoking injunctive relief and dismissing complaint – Appeals court affirming but modifying judgment to reflect dismissal not counting as ‘strike’ – United States Supreme Court granting inmate petition for writ of certiorari – Religious Land Use and Institutionalized Persons Act of 2000 (‘RLUIPA’), 42 USC s 2000cc-1(a)(1)-(2)

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