Answered Essay: Muhammad Holt, an Arkansas inmate and devout Muslim sued the Arkansas Department of

Muhammad Holt, an Arkansas inmate and devout Muslim sued the Arkansas Department of Corrections (an agency of the Arkansas State government).     The Arkansas Department of Corrections (ADC) has a grooming policy that prohibits inmates from growing beards unless they have a particular dermatological condition, but Holt wants to grow a half inch long beard in accordance with his religious beliefs.     If Holt proved his prima facie (on its face) case that (a) he is Muslim, (b) facial hair is an important element of his religious practice, and (c) the ADC refused to let him grow a beard, then did the burden of proof shift to the ADC to prove that the government’s grooming policy was the least restrictive means of furthering its compelling interests in stopping the flow of contraband?

Yes, the burden shifts to the ADC to prove the compelling interest for the restrictive grooming policy.
The burden of proof only shifts to the ADC if the judge or jury need more information to decide the case.
No, only the plaintiff in a case bears the burden of proof.

Expert Answer


Yes, the burden shifts to the ADC to prove the compelling interest for the restrictive grooming policy.

Under RLUPIA, the challenging party bears in the initial burden of proving that his religious exercise is grounded in sincerely held religious beliefs. and that government action substantially burdens his religious exercise. In this case, the challenging party (plantiff) satisfied his side of burden, so the burden now shifts to the ADC to prove the compellling interest of government to establish the restrictice grooming policy.

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