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First Liberty Briefing

First Liberty Briefing is an exclusive podcast hosted by First Liberty Institute’s Deputy General Counsel Jeremy Dys. In about 90-seconds, once a week, Jeremy recalls the stories that have shaped America’s religious liberty, from the founding era to current legal battles and more. It’s an insider’s look at the stories, cases, people, and laws that have made America the world’s leader in protecting religious liberty.
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May 30, 2018

Gregory Holt was granted permission by the Supreme Court to grow his beard while in prison in accordance with his Islamic faith. Listen at FirstLiberty.org/Briefing.


Gregory Holt is a felon serving time for his crime in a prison operated by the Arkansas Department of Corrections.  He is also known as Abdul Maalik Muhammed and, according to his Islamic faith, believed he should leave his beard uncut.

Well, there was a problem.  Prison regulations only permitted inmates to grow their beard one-quarter of an inch long.  Holt filed a lawsuit under the Religious Land Use and Institutionalized Persons Act, or RLUIPA, alleging that this restriction on beard growth was a substantial burden on the free exercise of his religion without a compelling justification. 

At the end of the day, the court found 9-0 that the regulation did in fact substantially burden the prisoner’s religion. The court reasoned that there were ways to accommodate even a violent felon’s religious exercise while also accomplishing its correctional goals. 

Holt v. Hobbsserves as an important reminder that even incarcerated felons retain at least some religious liberty. And, don’t forget “religious land use” is the first three letters in RLUIPA, meaning that this case also works to protect churches, synagogues, and religious ministries that are substantially burdened by the heavy hand of government that would substantially burden the free exercise of their religion without a compelling justification.

And that’s the remarkable story of how a felon’s beard protects your religious liberty.

To learn how First Liberty is protecting religious liberty for all Americans, visit FirstLiberty.org.

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