Gregory Holt v. Dexter Payne, No. 22-1809 (8th Cir. 2023)
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Plaintiffs sued the Arkansas Division of Corrections (ADC), alleging its policies violate the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA). After a bench trial, the district court dismissed the complaint. It found that their religious beliefs were not sincerely held; that even if they were sincerely held, the policies did not substantially burden those beliefs; and that even if there was a substantial burden, the policies were the least restrictive means to further ADC’s compelling interests. Plaintiffs appealed.
The Eighth Circuit vacated the judgment and remanded the case to the district court for further proceedings. The court explained that the district court found that ADC lacks the staff and space for separate Jumu’ah services. But Plaintiffs proposed alternatives, including utilizing other available spaces, partitioning the same space, and scheduling two Jumu’ah services in the same space at different times. The district court neither addressed these proposed alternatives to determine whether they were available or would effectively address ADC’s compelling security interests nor addressed whether the prison’s reasons for refusing to offer an accommodation were persuasive in light of the evidence that other prisons are able to do so. Correctly applying the governing law to Plaintiffs’ challenge requires that the court do so. Further, the court wrote that the district court also found that ADC’s religious headdress policy did not substantially burden Plaintiffs’ beliefs because ADC informally allows them to wear kufis in violation of the policy. But even if ADC does not enforce it consistently, the policy expressly prohibits Plaintiffs from wearing their kufis except during religious services.
Court Description: [Per Curiam - Before Kelly, Erickson, and Stras, Circuit Judges] Prisoner case - Religious Land Use and Institutionalized Persons Act of 2000. The Muslim plaintiffs challenge the Arkansas Department of Corrections policy limiting the wearing of kufis to religious services and banning their daily wear; plaintiffs also allege that the provision of only one Jumu'ah service, which is also attended by members of the Nation of Islam and Five-Percent Nation, violates their religious rights because their faith prohibits them from participating in Jumu'ah prayer with these other groups. The district court, following a bench trial, dismissed their complaint, finding that neither the single-service Jumu'ah policy nor the religious headdress policy substantially burdened plaintiffs' sincerely held religious beliefs or, alternatively, that the policies were the least restrictive means to further the Department's compelling security interests. The district court erred in its analysis as to whether the plaintiffs' beliefs regarding joint attendance with other groups was a sincerely held belief and whether the policy was a substantial burden on their broader belief that the policy required them to choose between abstaining from attendance or congregating, both of which would violate their religious beliefs; the district court also failed to consider plaintiffs' alternative arrangements which could address the Department's security concerns; the court erred in finding the policy regarding kufis did not burden plaintiffs' religious beliefs and erred in failing to address the plaintiffs' alternatives to the policy; reversed and remanded for further proceedings.
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