Holt v. Hobbs: The Court determined that preventing a prisoner from growing a half-inch beard in accordance with religious beliefs is illegal. Chisteson v. Roper: The Court determined that a lawyer's interest in avoiding damage to their own reputation is a conflict of interests if at odds with the client's strongest argument.
(9-0 Opinion by Justice Alito)
The Arkansas Department of Correction’s grooming policy violates the Religious Land Use and Institutionalized Persons Act of 2000 when it prevents a prisoner from growing a half inch beard in accordance with his religious beliefs.
The government argued that beards compromise prison safety because they can be used to hide contraband and can be shaved to quickly change appearance. The lower courts unanimously held that the policy met the RLUIPA because it was “the least restrictive means of furthering its compelling security interest.
Lower courts erred by holding that because there were “other ways” in which to practice his religion, the petitioner was not allowed to grow his beard. The District Court further erred in determining that the religious burden on the petitioner was slight because “his religion would ‘credit’ him for attempting to follow his religious beliefs.”
Therefore, the government failed to meet its burden here, because allowing a ½ inch beard, as requested by petitioner, would not compromise the governmental interest.
Christenson’s original habeas attorneys filed an untimely federal habeas petition. The lower courts erroneously denied a petition for substitute counsel. In determining whether a district court abused its discretion in denying such a motion, the court of appeals should consider “the timeliness of the motion; the adequacy of the district court’s inquiry into the defendant’s complaint; and the asserted cause for that complaint.” Martel v. Clair, 565 U.S., at ___(slip op., at 1).
The District Court’s primary error was not recognizing the original habeas attorney’s conflict of interest, in requiring them to denigrate their own performance. A “significant conflict of interest” arises when an attorney’s “interest in avoiding damage to [his] own reputation” is at odds with his client’s “strongest argument—i.e., that his attorneys had abandoned him.” Maples v. Thomas, 565 U.S.
Holding: A motion for substitution in a federal habeas petition should be granted when it is in the “interests of justice.”