Holt then filed a motion in court to require Arkansas allow him to grow a half-inch beard, arguing that he deserved an exception under the Religious Land Use and Institutionalized Persons Act.

The magistrate ultimately deferred to the judgment of the prison officials, relying on Eighth Circuit precedent, and recommended that Holt's motion be denied.

Arkansas had not overcome the high hurdles set by the law: that policymakers may not burden a person’s exercise of religion unless they can show a compelling governmental interest and that the policy was the least-restrictive means of achieving that goal.

In a concurrence, Justice Ginsburg, contrasting the case with Burwell v. Hobby Lobby, said accommodating Holt’s request "would not detrimentally affect others who do not share petitioner's belief.

"[6] In a separate concurrence, Justice Sotomayor disagreed with the majority's application of RLUIPA, but did agree that Arkansas officials did not adequately respond to Holt's request to keep a beard.