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Supreme Court Rules Unanimously That Muslim Prison Inmate Should Be Allowed to Grow a Beard

Samuel Alito wrote for the Court, and Ruth Bader Ginsburg and Sonia Sotomayor filed concurring opinions.

A Muslim prisoner in Arkansas can grow a beard in accordance with his religious beliefs, the Supreme Court ruled Tuesday.

The inmate, Gregory Holt, had been forbidden from growing a half-inch beard by the Arkansas prison administration because prison officials said the beard posed a safety hazard. Holt, also known as Abdul Maalik Muhammad, challenged the decision in court, and appealed to the Supreme Court in 2013.

The Supreme Court's unanimous opinion found that the Arkansas prison violated a federal law, the Religious Land Use and Institutionalized Persons Act, when it prevented Holt from growing a beard. The law states that "[n]o government shall impose a sub­stantial burden on the religious exercise" unless the government can show that the restriction is "the least restrictive means of furthering [a] compelling governmental interest."

The act requires that an inmate show that his or her religious exercise is "grounded in a sincerely held religious belief" and that the government is "substantially burdening" the religious exercise. Justice Samuel Alito, who prepared the Court's opinion, wrote that a lower court's challenges to Holt's religious beliefs were unfounded.

Next, the government must show that its restriction is absolutely necessary to fulfill a government interest—here, prison safety. This is where Alito was most forceful in his criticism of the Arkansas prison administration. He wrote that "without a degree of deference that is tantamount to unquestioning acceptance, it is hard to swallow the argument that denying petitioner a 1⁄2-inch beard actually furthers the department's interest in rooting out contraband."

Alito noted that Arkansas inmates are already allowed to wear quarter-inch beards, and that their hair and clothing are regularly searched. He wrote that the prison administration's argument that half-inch beards pose a significantly greater threat to the safety of prison officers and other inmates than quarter-inch beards do is difficult to believe.

The Court's opinion also took on the Arkansas prison administration's claim that longer beards make it easier for an inmate to disguise his identity. Alito rejected that argument, proposing a simple solution: prison officials should photograph inmates both with and without beards, he writes, to make it easier to identify them.

Justice Ruth Bader Ginsburg attached a one-sentence concurrence to the Court's opinion. In it, she stressed the difference between this case and last year's Hobby Lobby case. Unlike in Hobby Lobby, she wrote, "accommodating petitioner's religious belief in this case would not detrimentally affect others who do not share petitioner's belief."