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Reversed by Supreme Court, Eighth Circuit Remands Prisoner Grooming Case Back to District Court

by Christopher Zoukis

Arkansas state prisoner Larry Jones desired to grow a beard, as his religion required. Arkansas prison officials, citing an Arkansas Department of Corrections (ADC) policy disallowing beards, said no. Jones sued, claiming that the policy substantially burdened his exercise of religion, as prohibited by the Religious Land Use and Institutionalized Persons Act (RLUIPA).

The district court found for ADC officials, following precedent set by the Eighth Circuit in Holt v. Hobbs, 509 Fed. Appx. 561 (8th Cir. Ark. 2013). In Holt, the court ruled that the ADC grooming policy was not a violation of the RLUIPA because it was the least restrictive means of furthering a compelling penological interest.

Not so fast, said the United States Supreme Court. The Court took the Holt case up on certiorari and reversed, holding that the policy preventing growing a short beard violated the RLUIPA. This was fortuitous for Larry Jones, whose case was pending on appeal to the Eighth Circuit. In light of the Supreme Court's decision, the Eighth Circuit vacated the district court's ruling against Jones and remanded for a determination of whether Jones was entitled to relief under the Holt decision.

Subsequently, on remand, the district court entered judgment in favor of Jones and ordered prison officials to grant him a religious exemption to the ADC’s grooming requirements. He was also awarded costs of $805 for his filing fees.

See: Jones v. Meinzer,795 F.3d 776 (8th Cir. 2015).


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Related legal case

Jones v. Meinzer