Whether the Eleventh Circuit erred in applying RLUIPA when it held that Georgia need not grant a religious accommodation offered in 39 other prison systems

QUESTIONS PRESENTED In Knight v. Thompson, the Eleventh Circuit concluded—on remand following Holt v. Hobbs, 574 U.S. 352 (2015)—that the Religious Land Use and Institutionalized Persons Act allows denial of religious accommodations widely available in other jurisdictions whenever the prison makes a “calculated decision not to absorb [] added risks.” 797 F.3d 934, 937 (11th Cir. 2015). Here, it extended that logic to reject a beard-length accommodation available to religious adherents in at least thirty-nine other prison systems. It excused Georgia from any obligation to address the demonstrated safety of such accommodations in dozens of other states, instead relying only on the speculation of Georgia prison officials who admitted that they had not even attempted to determine how other _ states accommodate inmates with beards. The questions presented are: 1. Whether the Eleventh Circuit erred in applying RLUIPA when it held that Georgia need not grant a religious accommodation offered in 39 other prison systems. 2. Whether RLUIPA allows religious accommodations to be denied based on any plausible risk to penological interests, if the government merely asserts that it chooses to take no risks. 3. Whether RLUIPA prohibits courts from granting any religious accommodation short of the full accommodation sought by a plaintiff prisoner.