Gregory Holt (also known as Abdul Maalik Muhammad) felt that he was unable to practice his religion properly because the Arkansas Department of Corrections would not allow him to grow a beard longer than a quarter-inch. In Islam, growing a beard is part of their practiced religion.

The Eighth Circuit Court of Appeals ruled that the Arkansas Department of Corrections violated the Religious Land Use and Institutionalized Persons’ Act. Holt was protected under the Religious Land Use and Institutionalized Persons’ Act that is protected under the 1st Amendment of the United States Constitution, freedom of religion.

In Philadelphia, Pennsylvania, a devout Muslim firefighter by the name of Curtis DeVeaux refused to shave his beard because it went against his religious beliefs. Since he did not follow city regulations, he was released from his position.

The American Civil Liberties Union of Pennsylvania argued on DeVeaux's behalf. The Fire Department violated the Religious Freedom Protection Act, which is protected under the 1st Amendment of the Constitution. The Fire Department was made aware that Deveaux was a follower of Islam, but still persisted that he shave his beard due to their policies.