Holt V. Hobbs

HoltV. Hobbs

HoltV. Hobbs


TheArkansas Department of Corrections’ grooming policy does not breachthe &quotReligious Land Use and Institutionalized Persons Act&quotby obstructing Holt from keeping a one-half-inch beard to comply withhis faith values.



TheArkansas’ Department of Corrections’ grooming policy thatrestricts inmates from wearing any beard during their time inincarceration is critical as it helps inmates to maintain a standardappearance. Besides, shaved beards enhances hygiene as long facialhair can harbor parasites and dirt that can risk the health of aninmate (McDaniel &amp Curran, 2014, p. 4). Second, short facial hairprevents the possibility of prisoners manipulating their beardsdesign to disguise themselves. Facial appearance of an individualwith beards may look very different when he has shaved. This impliesthat prisoners with no beards will maintain a constant appearancethroughout the incarceration period and make it easy to track inmatesthat have escaped (Rasbach et al., 2014, p. 8). Third, inmates haveoccasionally smuggled into prison contraband stuff into the prisonswhile hiding them in the beards. In addition, inmates occasionallyconceal weapons in the beards while smuggling them into thecorrection facility (Shapiro et al., 2014, p. 9).

TheDepartment of Corrections only allows people with severe skinconditions only to keep long beards. However, other reasons that arenot associated with any given skin condition is unacceptable.Although the Religious Land Use and Institutionalized Persons Act of2000 (RLUIPA) states that the government should refrain from enactingpolicies that can prevent individuals from practicing their religiousbeliefs autonomously (McDaniel &amp Curran, 2014, p. 8). The actallows implementation of policies that are intended to attain a givengovernment interest with the least adverse effects on the concernedindividuals’ faith. Arkansas Department of Correction have compliedwith the regulation as it allows Muslims to continue practicing otherreligious beliefs independently (Shapiro et al., 2014, 12).

Thedefendants of the policy argue that if the policy is scraped away, itcould encourage good discipline among the Muslims. However, theassertions are mere hypothesis intended to justify bureaucraticstubbornness. The rationalization they use to justify deference tothe policy does not hold enough strength to justify the policydeference (Shapiro et al., 2014, p. 13).


Rassbachet al. (2014, p. 21)The Arkansas Department of Corrections’grooming policy breaches Holt’s RLUIPA rights as there areforty-four other states in the US that allow inmates to grow beardsin the prison similar to the size Arkansas state has banned. Theother states have similar security concerns with Arkansas thereby,the state is indirectly suppressing religious freedom (Rassbach etal., 2014, p. 21).

Inaddition, the petitioner contended that the discipline and healthissues used to justify the significance of implementing the policyare unfounded rationalizations intended to justify the introductionof regulations designed to oppress members of the minority faith. Theaction is troubling to the petitioner because it is a hostileindifference targeting religious minorities. The petitioners arelikely to that Arkansas Correction department is discriminating theMuslim minorities using the `Pigtail Ordinance` case (Rasbach et al.,2014, p. 9). In 1873, San Francisco proposed a law that would requireinmates to cut their hair for approximately one inch from theirscalp, supposedly, to enhance their personal hygiene. However, themayor vetoed the law because it was hostile towards the Han Chinesewho kept a pigtail extending to their waist. Holt could justifyhostility to the “no-beard rule” in Arkansas using the research(Rasbach et al., 2014, p. 10).

Thepetitioner can also justify the significance of growing beards usingthe “Holy Koran”. He could use “Sahih Al-Bukhari’s”teachings to prove that keeping beards is a logic “Hadith” amongMuslims. The text is among the most authoritative and reveredchapters in the Koran hence, it could serve as strong evidence tojustify the value of long keeping beards in Muslim faith (Rasbach etal., 2014, p.6).

Complainantmay also argue that allowing individuals to practice religiousfreedom enhances active rehabilitation and adjustment required tomaintain a peaceful environment in the market. Incarcerated personscan cause mayhem if the prison authorities embrace policies thatrestrain their freedom for practicing personal strategies.Furthermore, the petitioner is likely to argue that legitimacy andfairness is essential to achieve peaceful coexistence of inmates inthe correction department (Shapiro et al., 2014, p 14).


Shapiro,R.S., Trento, A.W., Fathi, D., Mach, D., Abram, J.L., &amp Marshal,R.C. (2014). GregoryHouston Holt AKA Abdul Malik Muhammad vs. Arkansas Department ofCorrection et al.The Supreme Court of the United States.

Rassbach,E.C., Laycock, D., Goodrich, L.W., Rienzi, M.L., Smith, H.C., Hawley,J.D. &amp Uddin, A.D. (2014). GregoryHouston Holt A/K/A Abdul Maalik Muhammad, PetitionerV. Ray Hobbs,Director, Arkansas Department Of Correction,Et Al.On writ of certiorari to the united states court of appeals for theeighth circuit.http://sblog.s3.amazonaws.com/wp-content/uploads/2014/05/13-6827-ts.pdf

McDaniel,D. &amp Curran, A.D. (2014). GregoryHouston Holt a/k/a Abdul Maalik Muhammad, V. Ray Hobbs, Director,Arkansas Department Of Correction, et al.The United States Supreme Court.