Settlement Reached in First Amendment Retaliation Case of Arkansas Jailhouse Litigator

LITTLE ROCK, Ark. — Gregory Holt, also known as Abdul Maalik Muhammad, has reached a settlement in his federal First Amendment retaliation lawsuit against the Arkansas Division of Correction, restoring him to the Larry B. Norris Unit and reinstating his legal work by assigning him to a job in the prison law library. The case, Holt v. Payne, alleged that Arkansas officials transferred Mr. Muhammad to a dangerous federal prison in retaliation for his constitutionally protected legal advocacy on behalf of himself and other incarcerated people.

Under the settlement, Mr. Muhammad will return to the Larry B. Norris Unit no later than Oct. 31, 2025, start a law library job by Nov. 14, and regain the ability to assist other prisoners with their legal work. The Arkansas Department of Corrections will also clear outstanding debts and certify compliance with the agreement to the court.

The court will retain jurisdiction to enforce the terms of the agreement and to decide the forthcoming motion for attorneys’ fees and costs.

“This settlement sends a clear message: the government cannot punish people for exercising their rights,” said John C. Williams, legal director of the ACLU of Arkansas. “Mr. Muhammad’s transfer was a blatant attempt to silence a man who has spent years defending civil rights from behind bars. Restoring his position and access to justice is not just a personal victory — it’s a reaffirmation of the First Amendment and the rule of law.”

“We just wanted to bring Mr. Muhammad back home to Arkansas,” added Carolyn Homer, counsel at Morrison Foerster LLP. “Now he can resume the civil rights work that has long been an inspiration for incarcerated people statewide.”

“I always knew that justice would prevail, and today it has,” Mr. Muhammad said.

Mr. Muhammad, known nationally for his 2015 U.S. Supreme Court victory defending the religious liberty rights of people in prison (Holt v. Hobbs), has continued to challenge unconstitutional conditions and practices in Arkansas prisons for over a decade. In July 2025, the ACLU of Arkansas and Morrison Foerster filed suit after state officials transferred him to USP Hazelton in West Virginia — a facility notorious for violence — following a failed mediation in one of his pending civil rights cases.

The lawsuit argued that this retaliatory transfer was designed to disrupt his ongoing litigation and deter others from exercising their constitutional right to petition the government for redress.

With today’s settlement, Mr. Muhammad’s hard-fought return marks not only the restoration of one man’s rights but a warning against the misuse of state power to silence dissent.

A copy of the settlement can be found online here.