RLUIPA

Holt v. Hobbs

Issues

Does a prison’s grooming policy, which prohibits all beards except for quarter-inch beards for certain medical reasons, violate the Religious Land Use and Institutionalized Persons Act by prohibiting an inmate from growing a half-inch beard in accordance with his religious beliefs?

In 2000, Congress enacted the Religious Land Use and Institutionalized Persons Act (“RLUIPA”) with the intent to provide protection for the free exercise of religion in various contexts, including prisons and jails. In this case, the Supreme Court will consider whether a prison grooming policy prohibiting a half-inch beard grown in accordance with a prisoner’s religious beliefs, violates RLUIPA. Additionally, the Court will have the opportunity to determine the level of deference courts should give prison officials when considering whether a prison policy that substantially burdens inmates’ exercise of religion furthers a compelling governmental interest and is the least restrictive means available. The resolution of this case may impact the balance between the rights of prisoners to practice their religion freely while incarcerated and the government’s interest in prison safety. 

Questions as Framed for the Court by the Parties

  1. Whether the Arkansas Department of Corrections’ no beard grooming policy violates the Religious Land Use and Institutionalized Persons Act (RLUIPA).
  2. Whether a ½ inch beard would satisfy the security goals sought by the policy.
  3. Whether the no beard grooming policy violates Petitioner’s First Amendment right to practice Islam as he believes it is supposed to be practiced by the wearing of the beard.
  4. That the United States Court of Appeals for the Eighth Circuit has decided that the no beard grooming policy does not violate the RLUIPA, but this Court should decide the matter since it has not done so and should rule whether grooming policies of any Department of Correction that do not allow for a religious exception exemption are constitutional.
  5. That the United States Court of Appeals for the Eighth Circuit’s decision in this case conflicts with other circuit’s rulings on the matter.
  6. That the ADC grooming policy of no beards is not the least restrictive means of achieving the desired objective of staunching the flow of contraband and identifying prisoners in the event of an escape.

In 2000, Congress enacted the Religious Land Use and Institutionalized Persons Act (“RLUIPA”) to provide protection for the free exercise of religion in several contexts, including incarceration. See 42 U.S.C.

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Sossamon v. Texas

Issues

Whether the term “appropriate relief” as provided in the Religious Land Use and Institutionalized Persons Act should be interpreted to include monetary damages or instead should be interpreted to include only injunctive and declaratory relief?

 

Harvey Leroy Sossamon, III is an inmate at a Texas state prison. The prison warden refused to allow cell-restricted inmates to attend religious services and denied all inmates use of the prison chapel for religious purposes. In 2006, Sossamon filed suit against the State of Texas and various state and prison officials, alleging that the Texas prison violated the Religious Land Use and Institutionalized Persons Act ("RLUIPA"). Sossamon sought declaratory and injunctive relief, as well as compensatory and punitive damages. The District Court granted summary judgment in favor of Texas, holding that Texas has sovereign immunity under the 11th Amendment and is not liable for damages. The Fifth Circuit affirmed. Sossamon argues here that the words “appropriate relief,” as provided by RLUIPA, unambiguously waives the state's immunity from damages. Texas counters that “appropriate relief” does not amount to clear notice which is required before a state may waive its sovereign immunity. The Supreme Court’s decision in this case will determine the protection afforded to states under RLUIPA and may deter states from implementing policies which violate the Act.

Questions as Framed for the Court by the Parties

Whether an individual may sue a state or state official in his official capacity for damages for violations of the Religious Land Use and Institutionalized Persons Act, 42 U.S.C. §2000cc et seq. (2000 ed.).

Petitioner Harvey Leroy Sossamon, III has been an inmate of the Robertson Unit of the Correctional Institutions Division of the Texas Department of Criminal Justice since 2002. See Brief of Respondents, Texas et al.

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