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Religious beards in prison

Gregory Houston Holt v. Hobbs

Updated Oct 18, 2026

In brief

The Supreme Court sided with Holt: Arkansas could not use its grooming policy to bar his religious half-inch beard.

Where it stands
Decided

Decided 9-0 · January 20, 2015 · Opinion by Justice Ginsburg

What it’s about
The Supreme Court ruled that Arkansas’s prison grooming policy violated the federal Religious Land Use and Institutionalized Persons Act, a law protecting religious practice in institutions, insofar as it stopped Gregory Holt from growing a half-inch beard for religious reasons.
Who it affects
Arkansas’s prison system cannot use this grooming policy to stop Holt from growing a half-inch beard in line with his religious beliefs.

Summary: written with AI from the case record.

Illustration for Gregory Houston Holt, aka Abdul Maalik Muhammad v. Ray Hobbs, Director, Arkansas Department of Correction
Conceptual illustration · AI-generated

What it's about

It overturned the lower court’s ruling (reversed it) and sent the case back to that court (remanded it).

The Religious Land Use and Institutionalized Persons Act protects religious practice in institutions, including prisons.

Question presented

Does the Arkansas Department of Corrections grooming policy violate the Religious Land Use and Institutionalized Persons Act by preventing Holt from growing a one-half-inch beard in accordance with his religious beliefs?

What the Court decided

Holding

The Department’s grooming policy violates RLUIPA insofar as it prevents petitioner from growing a ½-inch beard in accordance with his religious beliefs. 561, reversed and remanded.

Result
Reversed

The Court's reasoning

Justice Sotomayor, writing separately, said the Department had not shown why less restrictive options Holt identified would fail to serve its security interests. She stressed that prison security remains a compelling interest and prison officials deserve deference.

The vote

  • Joined the judgment
  • Wrote an opinion
Majority · 9joined the Court's opinion
  1. Breyer
  2. Kagan
  3. Thomas
  4. Scalia
  5. Kennedy
  6. Ginsburgwrote the opinion
  7. Sotomayoralso wrote separately
  8. Roberts
  9. Alitoalso wrote separately
9 justices joined the judgment.

What's next

The case returns to the Eighth Circuit to proceed under the Supreme Court’s ruling.

Documents

1

Opinions

  • Holt

    Alitodelivered, Sotomayor

View the full docket on supremecourt.gov

Docket activity

6
  • New analysis added

    Oct 18, 2026 · Court records

  • AI analysis generated: Case Briefing

    Oct 18, 2026 · Generated

  • AI analysis generated: Decision Record

    Oct 18, 2026 · Generated

  • Case data updated: summary, question_presented, generation_metadata

    Oct 18, 2026 · Court records

  • Case data updated: question_presented, extraction_metadata

    Oct 17, 2026 · Court records

Show 1 more
  • Opinion added: Holt

    Jan 20, 2015 · Court records

Sources

Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.

Checked Oct 18, 2026Methodology

Court records and filings

Reporting and analysis