Harris v. Muhammad

Background

Maurice Lydell Harris, an inmate currently housed at Corcoran State Prison, filed this civil-rights action under 42 U.S.C. § 1983 without a lawyer. He alleges that prison officials denied him a diet that complies with his religious faith and provides adequate nutrition.

Harris says the California Department of Corrections and Rehabilitation’s Religious Meal Alternative Program, or RMAP, best accommodates the dietary requirements of his Nichiren Buddhist faith. He sometimes eats ramen soups to supplement the RMAP meals. According to the opinion, those soups comply with his stated dietary requirements but not with Islamic dietary laws. Prison officials conditioned his continued participation in RMAP on following Islamic dietary laws.

Harris’s claims allege violations of the First Amendment’s protection for religious exercise, the Religious Land Use and Institutionalized Persons Act, the Equal Protection Clause, and the Eighth Amendment’s prohibition on deliberate indifference to serious medical needs.

Harris began the case while housed at San Quentin Rehabilitation Center and named officials there who had authority over religious-diet enrollment. After he was transferred to Corcoran State Prison, Corcoran officials removed him from RMAP after two notices of noncompliance within a six-month period, based on his purchase of food containing non-halal-certified meats.

Earlier Requests for Emergency Relief

Harris twice asked the court for a temporary restraining order or preliminary injunction. A preliminary injunction is a court order issued before final judgment that requires or prohibits certain conduct while the case continues.

The court denied his first request in 2022. It reasoned that RMAP did not provide the GMO-free diet Harris said his religion required, that leaving RMAP would not prevent him from practicing his religion, and that he could use other diets and food purchases to meet his nutritional and religious needs.

After his removal from RMAP, Harris filed a renewed request seeking re-enrollment and permission to remain in RMAP while purchasing items containing non-halal-certified meat. The court denied that request in an April 23, 2024 order. At that time, the court concluded that Harris had not shown that RMAP matched his religious beliefs and that removal from RMAP therefore did not substantially burden his religious exercise.

Ninth Circuit Decision

The Ninth Circuit later held that the district court had erred in deciding that Harris was unlikely to succeed on his claim under the Religious Land Use and Institutionalized Persons Act. The appeals court said the district court had improperly assessed what diet Harris’s Nichiren Buddhist faith required instead of focusing on Harris’s own understanding of his faith.

The Ninth Circuit concluded that Harris had sufficiently shown a substantial burden on his religious exercise because, as he understood and interpreted his faith, removal from RMAP forced him to choose between his religious diet and possible prison consequences. The appeals court explained that a court may examine whether a belief is sincerely held, but may not decide whether a practice is central to the person’s religion or determine what the religion requires.

The Ninth Circuit sent the matter back for the district court to reconsider whether Harris had made an initial showing of a substantial burden. It also stated that the government had not yet established that removing Harris from RMAP was the least restrictive means of achieving a compelling interest, as required for the government to prevail on the Religious Land Use and Institutionalized Persons Act claim.

Ruling in This Order

The district court stated that, regardless of the role halal meat played in Harris’s religious practice, the Ninth Circuit had found that Harris’s belief that RMAP was necessary to practice his faith was enough to show a substantial burden for purposes of further consideration.

Judge Haywood S. Gilliam, Jr. therefore vacated the portion of the April 23, 2024 order denying Harris’s request for a temporary restraining order and preliminary injunction. The court reopened the action and ordered supplemental briefing on three issues: whether Harris had stated a sincere religious belief; if so, whether removing him from RMAP was the least restrictive means of achieving the California Department of Corrections and Rehabilitation’s compelling interest; and whether Harris still had standing to seek injunctive relief against the current defendants after his transfer to Corcoran State Prison. The court also asked whether Harris would seek to amend the operative complaint to name the proper defendant.

The court required defendants to file supplemental briefing by April 10, 2026, and Harris to file his supplemental briefing by May 11, 2026. It set July 10, 2026, as the deadline for defendants’ dispositive motion and established deadlines for Harris’s opposition and defendants’ reply. The order did not decide the preliminary-injunction request on the merits or resolve Harris’s underlying claims.