Harris v. Broomfield

Background

Maurice Lydell Harris, an inmate at San Quentin State Prison, brought this civil-rights action without a lawyer under 42 U.S.C. § 1983. The opinion says the operative complaint asserted claims under the First Amendment’s protection for religious exercise, the Eighth Amendment, the Equal Protection Clause, and the Religious Land Use and Institutionalized Persons Act.

Harris practices Soka Gakkai International Nichiren Buddhism. He alleged that his religious beliefs require him to avoid meat containing genetically modified ingredients. He enrolled in the prison’s Religious Meat Alternate Program, or RMAP, which the opinion describes as the prison’s halal or Islamic diet. Harris said he was permitted to participate based on his Nichiren Buddhist dietary restrictions and had not signed the prison’s Religious Diet Agreement.

The prison officials stated that San Quentin did not offer a GMO-free diet and that RMAP provided halal-certified meat, not GMO-free food. Harris had supplemented RMAP meals with non-halal canteen purchases, including ramen soups, oysters, and beef products. He received religious-diet violations for some of those purchases and was told that continued purchases of non-Islamic food could result in removal from RMAP unless he withdrew voluntarily. Harris reported light-headedness, lethargy, and brain fog when he could not supplement the diet.

Motion and parties’ positions

Harris moved for a temporary restraining order and preliminary injunction—temporary court orders intended to prevent or require conduct while a case continues. He asked the court to prohibit the defendants from denying him the ability to supplement RMAP with non-halal or non-kosher food from the prison canteen or vendors.

Harris argued that he was likely to succeed because his religious-liberty claim was subject to strict review, the defendants had not identified a compelling governmental interest, and he had previously been allowed to buy non-halal food. He also argued that he faced irreparable harm, that the balance of hardships favored him, and that the requested relief served the public interest.

The defendants argued that the court lacked jurisdiction over the people who issued the 2021 and 2022 violations because they were not named defendants. They also argued that Harris was not receiving a GMO-free diet, that the prison did not offer one, and that he had not shown anyone threatened to remove him from RMAP. They contended that the prison’s review of inmates’ eligibility for religious diets served a legitimate goal of reducing costs associated with specialized meals.

Court’s analysis

The court applied the standards for temporary restraining orders and preliminary injunctions. Harris had to show a likelihood of success on the merits or, under the alternative sliding-scale approach, serious legal questions; a likelihood of irreparable harm without an order; that the balance of equities favored him; and that the order would serve the public interest. The Prison Litigation Reform Act also required any prospective relief concerning prison conditions to be narrowly drawn, no broader than necessary, and the least intrusive means of correcting the harm.

The court denied the request because it found Harris unlikely to succeed on the merits. The court reasoned that RMAP was not the GMO-free diet Harris said his religion required. Therefore, the court concluded that removing Harris from RMAP would not prevent him from following his asserted religious dietary requirements. For the same reason, the court concluded that requiring Harris to follow RMAP’s restrictions did not treat him differently from Jewish or Muslim inmates and did not violate the Eighth Amendment.

The court further concluded that Harris could choose another diet, or leave RMAP, and supplement his food purchases to meet his nutritional and health needs. It therefore found no irreparable harm from possible removal from RMAP, determined that the balance of equities did not favor Harris, and concluded that the requested relief would not serve the public interest.

Disposition

The court denied Harris’s request for a temporary restraining order and preliminary injunction barring the defendants from preventing him from supplementing RMAP with non-halal or non-kosher food from the prison canteen or vendors. The court did not rule on a request that prison officials provide a GMO-free diet because the opinion says Harris had not raised that claim in this action. The court stated that he could amend the complaint to bring such a claim and reminded him that civil-rights claims must satisfy the requirement to exhaust administrative remedies. Judge Haywood S. Gilliam, Jr. signed the order.