In Holt v. Hobbs, 135 S.Ct. 853 (2015), the Supreme Court held that a prison’s grooming policy that prohibited inmates from growing ½-inch beards violated the Religious Land Use and Institutionalized Persons Act because it imposed a substantial burden on the inmate’s exercise of his Muslim faith. The court held that general safety and security concerns (stopping the flow of contraband and allowing guards to quickly identify inmates) were not a compelling enough interest to justify the policy (particularly when the prison permitted ¼-inch beards and did not regulate the length of head hair), and that there were less restrictive ways to monitor contraband (including manually searching an inmate’s beard) and identify inmates in restricted areas (take clean shaven and bearded photographs).