Holt v. Hobbs

135 S. Ct. 853, 190 L. Ed. 2d 747, 25 Fla. L. Weekly Fed. S 43, 93 A.L.R. Fed. 2d 777, 2015 U.S. LEXIS 626, 83 U.S.L.W. 4065
CourtSupreme Court of the United States
DecidedJanuary 20, 2015
Docket13–6827.
StatusPublished
Cited by342 cases

This text of 135 S. Ct. 853 (Holt v. Hobbs) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Holt v. Hobbs, 135 S. Ct. 853, 190 L. Ed. 2d 747, 25 Fla. L. Weekly Fed. S 43, 93 A.L.R. Fed. 2d 777, 2015 U.S. LEXIS 626, 83 U.S.L.W. 4065 (U.S. 2015).

Opinions

Justice ALITOdelivered the opinion of the Court.

Petitioner Gregory Holt, also known as Abdul Maalik Muhammad, is an Arkansas inmate and a devout Muslim who wishes to grow a ½-inch beard in accordance with his religious beliefs. Petitioner's objection to shaving his beard clashes with the Arkansas Department of Correction's grooming policy, which prohibits inmates from growing beards unless they have a particular dermatological condition. We hold that the Department's policy, as applied in this case, violates the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), 114 Stat. 803, 42 U.S.C. § 2000cc et seq.,which 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.

We conclude in this case that the Department's policy substantially burdens petitioner's religious exercise. Although we do not question the importance of the Department's interests in stopping the flow of contraband and facilitating prisoner identification, we do doubt whether the prohibition against petitioner's beard furthers its compelling interest about contraband. And we conclude that the Department has failed to show that its policy is the least restrictive means of furthering its compelling interests. We thus reverse the decision of the United States Court of Appeals for the Eighth Circuit.

I

A

Congress enacted RLUIPA and its sister statute, the Religious Freedom Restoration Act of 1993 (RFRA), 107 Stat. 1488, 42 U.S.C. § 2000bb et seq.,"in order to provide very broad protection for religious liberty." Burwell v. Hobby Lobby Stores, Inc.,573 U.S. ----, ----, 134 S.Ct. 2751, 2760, 189 L.Ed.2d 675 (2014). RFRA was enacted three years after our decision in Employment Div., Dept. of Human Resources of Ore. v. Smith,494 U.S. 872, 110 S.Ct. 1595, 108 L.Ed.2d 876 (1990), which held that neutral, generally applicable laws that incidentally burden the exercise of religion usually do not violate the Free Exercise Clause of the First Amendment. Id.,at 878-882, 110 S.Ct. 1595. Smithlargely repudiated the method of analysis used in prior free exercise cases like Wisconsin v. Yoder,406 U.S. 205, 92 S.Ct. 1526, 32 L.Ed.2d 15 (1972), and Sherbert v. Verner,374 U.S. 398, 83 S.Ct. 1790, 10 L.Ed.2d 965 (1963). In those cases, we employed a balancing test that considered whether a challenged government action that substantially burdened the exercise of religion was necessary to further a compelling state interest. See Yoder,supra,at 214, 219, 92 S.Ct. 1526; Sherbert, supra,at 403, 406, 83 S.Ct. 1790.

Following our decision in Smith,Congress enacted RFRA in order to provide *860greater protection for religious exercise than is available under the First Amendment. See Hobby Lobby, supra,at ---- - ----, 134 S.Ct., at 2760-2761. RFRA provides that "[g]overnment shall not substantially burden a person's exercise of religion even if the burden results from a rule of general applicability," unless the government "demonstrates that application of the burden to the person-(1) is in furtherance of a compelling governmental interest; and (2) is the least restrictive means of furthering that compelling governmental interest." 42 U.S.C. §§ 2000bb-1(a), (b). In making RFRA applicable to the States and their subdivisions, Congress relied on Section 5 of the Fourteenth Amendment, but in City of Boerne v. Flores,521 U.S. 507, 117 S.Ct. 2157, 138 L.Ed.2d 624 (1997), this Court held that RFRA exceeded Congress' powers under that provision. Id.,at 532-536, 117 S.Ct. 2157.

Congress responded to City of Boerneby enacting RLUIPA, which applies to the States and their subdivisions and invokes congressional authority under the Spending and Commerce Clauses. See § 2000cc-1(b). RLUIPA concerns two areas of government activity: Section 2 governs land-use regulation, § 2000cc; and Section 3-the provision at issue in this case-governs religious exercise by institutionalized persons, § 2000cc-1. Section 3 mirrors RFRA and provides that "[n]o government shall impose a substantial burden on the religious exercise of a person residing in or confined to an institution ... even if the burden results from a rule of general applicability, unless the government demonstrates that imposition of the burden on that person-(1) is in furtherance of a compelling governmental interest; and (2) is the least restrictive means of furthering that compelling governmental interest." § 2000cc-1(a).

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135 S. Ct. 853, 190 L. Ed. 2d 747, 25 Fla. L. Weekly Fed. S 43, 93 A.L.R. Fed. 2d 777, 2015 U.S. LEXIS 626, 83 U.S.L.W. 4065, Counsel Stack Legal Research, https://law.counselstack.com/opinion/holt-v-hobbs-scotus-2015.