Lester J. Smithv.Brian Owens
Lester J. Smith, a Muslim prisoner, challenged a prison grooming policy that required him to cut his beard despite his religious belief that Islam required an uncut beard. The district court granted summary judgment to the prison official under the Religious Land Use and Institutionalized Persons Act. The Eleventh Circuit vacated and remanded. The district court had applied an evidentiary record developed under an earlier policy and had not analyzed Smith’s claim under the prison system’s revised grooming policy and the Supreme Court’s intervening decision in Holt v. Hobbs. The appellate court explained that the revised policy and the record concerning Smith’s sincere religious exercise required a fresh statutory analysis rather than mechanical reliance on an earlier case involving different evidence. The court did not decide whether the policy ultimately violated the Act. It directed the district court to reconsider the claim on the proper record and legal framework.
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