Native American Inmates in the Alabama Department of Corrections: Knight v. Thompson

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In Knight v. Thompson, Native American inmates in the Alabama Department of Corrections (ADOC) prison system challenged an ADOC policy restricting inmates’ hair length under the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), 42 U.S.C. § 2000cc-1(a). The policy required all male inmates to have a “regular hair cut.” The ADOC did not grant any exceptions to this policy. The policy was originally challenged by the plaintiffs as a violation of the Religious Freedom Restoration Act (RFRA). After the Supreme Court declared RFRA unconstitutional, Congress enacted the RLUIPA and the plaintiffs were allowed to amend their complaint. After the plaintiffs won a summary judgment appeal and were granted a bench trial, the district court ruled that despite its substantial burden on the plaintiff’s religious exercise, the ADOC’s hair length policy did not violate the RLUIPA because the ADOC had compelling interests in security, health, and hygiene and the policy was the least restrictive means of achieving these interests.
On appeal, the main questions for the court were whether the ADOC’s short-hair policy furthered the prison system’s compelling interests and whether it was the least restrictive means of furthering those interest. The court affirmed the district court’s ruling. The court rejected a strict proof requirement and held that in order to meet the RLUIPA’s least restrictive means burden, prison officials are not required to show that they considered other less restrictive alternatives before adopting the policy in question.
The issue of whether the RLUIPA requires prison officials to consider less restrictive alternatives has been addressed by other circuits. In Warsoldier v. Woodford, ei...

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...soldier requires institutions to take precautions at the outset when forming their policies.
Granting deference to the judgment of prison administrators, the Knight court held that RLUIPA does not require prison administrators to actually consider and reject alternatives in order to show the policy in question is the least restrictive means of achieving a compelling interest. Overall, the Knight decision creates more confusion than clarity for interpreting RLUIPA because of its rejection of prior case law. The Eleventh Circuit seems to be alone in its interpretation, as the Tenth Circuit recently adopted the strict proof requirement in Yellowbear v. Lambert, requiring the defendants to “refute . . . alternative schemes.” Although RLUIPA “mandates a uniform test, not a uniform result,” the Knight decision creates neither a uniform test nor uniform results.

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