An arkansas prison policy prohibiting beards was struck down as a violation of a muslim man's ability to freely exercise his religion in the case of

This was the case of "Holt v. Hobbs". In this case, Holt, a practicing Salafi Muslim, claimed that the imposition of facial hair restrictions were an imposition based upon the Religious Land Use and Imprisoned Persons Act. The 9-0 majority found that the prison had not exhausted all available measures for accommodating Mr. Holt and that the grooming policy was an imposition against his religious needs.