Muslim Prisoner Denied Right To Wear Beard

In Gooden v. Grain, 2005 U.S. Dist. LEXIS 32960 (ED Tex., Dec. 13, 2005), a Texas federal district court rejected the RLUIPA and equal protection claims of a Muslim prisoner who was prevented by the Texas prison system's grooming policy from growing a quarter-inch beard. The court held that the grooming policy did not not impose a substantial burden on the prisoner's practice of his religion. Alternatively, even if it did impose a substantial burden, it furthers the compelling governmental interest of security and does so by the least restrictive means. Finally the court found that the policy applied equally to all religious groups and was not adopted with the intent to discriminate against Muslims.