The Supreme Court held unanimously in Holt v. Hobbs that an inmate’s rights under the Religious Land Use and Institutionalized Persons Rights Act (RLUIPA) were violated when he was not allowed to grow a half inch beard in accordance with his religious beliefs.  RLUIPA states that the government may not substantially burden the free exercise of an institutionalized person unless the burden is the least restrictive means of furthering a compelling government interest.  While the Court agreed that preventing the flow of contraband in it facilities and preventing prisoners from disguising their identities are compelling state interests, it concluded disallowing half inch beards isn’t the least restrictive means of furthering prison safety and security.  The Department’s concern that prisoners may hide contraband in their beards was “hard to take seriously.”  Only small items could be concealed, inmates could more easily conceal items in head hair, and beards can be searched.  Photographing an inmate with and without a beard would solve the problem of an inmate changing his appearance to enter restricted areas, escape, or evade apprehension upon escaping.  And the fact that the Department allows inmates to grow mustaches, head hair, and quarter inch beards for medical reasons, all of which could be shaved off at a “moment’s notice,” indicate security concerns raised by quickly changing appearance are not “serious.”