Holt v. Hobbs Amicus Briefs

Diverse Religious, Civil Rights Groups Join Forces to Protect Prisoner Religious Liberty

Many Groups filed briefs in support of Mr. Muhammad, including:

  • The United States
  • Former prison wardens and prisoners
  • Prison ministries
  • Women’s Prison Association
  • Islamic Law Scholars
  • Social Scientists
  • Christians
  • Muslims
  • Sikhs
  • Native Americans
  • Hindus
  • Jews
  • Advocacy Groups (ACLU, ADF)

List of Amicus Briefs:

  • The United States: Solicitor General Donald B. Verrilli, Jr.
  • Christian Groups: Prison Fellowship Ministries, World Vision, National Association of Evangelicals, and Christian Legal Society
  • Islamic Law Scholars: Jonathan A. Brown, Associate Professor of Islamic Studies and Muslim-Christian Understanding at Georgetown University; Khaled M. Abou El Fadl, Omar and Azmeralda Alfi Professor of Law at the UCLA School of Law; John L. Esposito, University Professor and Professor of Religion and International Affairs of Islamic Studies at Georgetown University; Mohammad Fadel, Canada Research Chair for the Law and Economics of Islamic Law and Associate Professor of Law at the University of Toronto Faculty of Law; Ingrid Mattson, London and Windsor Community Chair in Islamic Studies and Windsor Community Chair in Islamic Studies at Huron University College at the University of Western Ontario
  • Reformed Prisoners: Jesse Wiese, Policy Analyst at Justice Fellowship, an arm of Prison Fellowship Ministries who developed a relationship with Jesus Christ during his 15 years in prison; Nicholas Robbins, a Reentry Specialist at Pathway to Freedom who developed a relationship with God during his ten-year sentence; Thomas C. Cotton, III, Executive Director of Redemption & Advancement Alliance, who developed a relationship with Jesus Christ during his ten years in prison; Ernst Fenelon, Program Coordinator at the Prison Education Project who became a devout Muslim during his 14 years in prison; and Scott Greenberg, charity volunteer and teacher who reconnected with his Jewish faith during his six-year sentence and credits his good conduct post-release to the prison Jewish program
  • Former Prison Wardens: Jeann Woodford, Senior Distinguished Fellow at the Chief Justice Earl Warren Institute on Law and Social Policy at University of California, Berkeley School of Law and former warden of California’s San Quentin State Prison; Dr. Reginald A. Wilkinson, President and CEO of the Ohio College Access Network and former warden of Ohio’s Dayton Correctional Institution, past president of the American Correctional Association, the Association of State Correctional Administrators, and the International Association of Reentry; Richard Subia, Public Safety Consultant and member of the Heald College Criminal Justice Advisory Board and former Correctional Officer, Correctional Sergeant, Correctional Lieutenant, Correctional Administrator, and statewide Director of the Division of Adult Institutions; Dr. Allen Ault, Dean of the College of Justice & Safety at Eastern Kentucky University and former warden for Georgia’s Diagnostic and Classifications Prison, a maximum security prison
  • Jewish Organizations: National Jewish Commission on Law and Public Affairs, Agudath Harabbanim of United States and Canada, Agudath Israel of America, Aleph Institute, Rabbinical Alliance of America, Rabbinical Council of America, National Council of Young Israel, Union of Orthodox Jewish Congregations of America
  • Former Corrections Officials (represented by the ACLU): John Clark, Justin Jones, Chase Riveland, Phil Stanley, and Eldon Vail
  • Social Scientists: Dr. Ronald L. Akers, Professor Emeritus of Criminology and Sociology at the University of Florida; Dr. Byron R. Johnson, Baylor University’s Distinguished Professor of the Social Sciences, founding director of the Institute for Studies of Religion and one of the leading authorities on the efficacy of religion on behavior and recidivism rates in prison populations; and Dr. Sung Joon Jang, Associate Professor of Sociology at Baylor University whose areas of research include crime and deviance, juvenile delinquency, and religiosity and spirituality.
  • Jewish Groups: American Jewish Community, Union for Reform Judaism, Central Conference of American Rabbis, Women of Reform Judaism, Baptist Joint Committee for Religious Liberty in Support of Petitioner
  • Religious Denominations: International Mission Board for the Southern Baptist Convention, United States Conference of Catholic Bishops, Islamic Shura Council of Southern California, Jewish Prisoner Services International, Lutheran Church-Missouri Synod, Stated Clerk of the General Assembly of the Presbyterian Church (U.S.A.), General Conference of Seventh-Day Adventist, and General Synod of the United Church of Christ
  • Religious Groups: Anti-Defamation League, the International Society for Krishna Consciousness, Muslim Advocates, the Queens Federation of Churches, and the Sikh American Legal Defense and Education Fund
  • Sikh Coalition and Muslim Public Affairs Council
  • Women’s Prison Association
  • Americans United for the Separation of Church and State
  • National Congress of American Indians and Huy
  • Alliance Defending Freedom
  • The Rutherford Institute


  • “It is amici’s experience that allowing prisoners latitude to exercise their religious beliefs as they see fit enables prison administrators to harness the positive influence of religion in the prison setting.” – Brief of Former Corrections Officials
  • “Sincere development and practice of religion in prison literally helps ‘convert’ violent and dangerous men into upstanding citizens—a process that in modern prisons needs all the help it can get.” – Brief of Reformed Prisoners
  • “Robert Iron Eyes, a Standing Rock Sioux, had only five haircuts in his twenty-seven years: three in mourning for the death of a loved-one and two at the hands of his jailors. . . . Iron Eyes described the experience: . . . ‘[Captain] Rosenburg and about 9 or 10 other guards handcuffed me behind my back real hard and put leg shackles on me . . . Then, Dan Henry, the [Assistant Superintendent] said that I am going to get a haircut one way or the other and that they didn’t care if I was Geronimo. I told them that the courts also said us Indians could keep our hair and Dan Henry said for me and the court to go and fuck ourselves [sic]. I am sorry about that word but that is what he really said. . . . [T]he guards all took my leg shackles and handcuffs real hard and held me down and this inmate barber named Earl Wells came over and cut my hair into a raggedy mess. That is when they all started laughing and [Major] Harris said that now I could get some white religion.’” – Brief of National Congress of American Indians and Huy
  • “A series of studies shows that even relatively modest religious involvement in prison is one of the most significant factors in reducing the recidivism rate of released prisoners.” – Brief of Social Scientists
  • “[Failure to enforce RLUIPA] creates space for prejudice and discrimination; allows for bias, ignorance, and fear to dictate prison policies; and leaves inmates who practice nonmainstream religions bereft of the legal protection Congress guaranteed to them when it passed RLUIPA.” – Brief of the Sikh Coalition and Muslim Public Affairs Council
  • “Prohibiting a half-inch beard maintained for religious purposes is far from the least restrictive method of preventing contraband secretion; in fact, it is probably one of the least effective solutions to that problem.” – Brief of Former Prison Wardens
  • “Emerging empirical research suggests that there are significant societal benefits to accommodating religious practice in prisons. It is therefore counterproductive as a matter of public policy to interfere with prisoners’ religious observance.” – Brief of Religious Denominations

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