Harris v. Broomfield

Background

Maurice Lydell Harris, an incarcerated person representing himself, brought this civil-rights action under 42 U.S.C. § 1983. The case concerns his participation in the California Department of Corrections and Rehabilitation’s Religious Meat Alternate Program (RMAP). Harris practices Nichiren Buddhism and describes his religious dietary requirements as eating “wisely” or “cleanly,” including eating organic foods and avoiding highly processed, artificial, synthetic, genetically modified, or chemically named foods.

Harris enrolled in the RMAP in 2011 after Rabbi Hyman told him that the program best complemented his religious dietary needs. The RMAP provides halal-certified meat as a substitute at dinner when meat is served, but the record did not show that it provides GMO-free or organic food, or that it avoids highly processed, artificial, or synthetic foods. Harris purchased ramen and other items from the prison canteen to supplement his RMAP meals when he believed the meals were nutritionally or calorically insufficient or when he did not receive an RMAP meal.

Prison officials issued Harris notices of noncompliance with the RMAP. The record identified purchases between August 8 and November 3, 2023, including ramen and other foods containing non-halal-certified meats. After Harris received two notices within six months, Corcoran staff removed him from the RMAP. The opinion states that defendant Richey did not issue the notices, review the violations, or make the removal decision.

Requests before the court

Harris renewed his request for a temporary restraining order and preliminary injunction. These are emergency court orders intended to prevent ongoing harm or preserve the parties’ positions while a case continues. He asked the court to require defendants to re-enroll him in the RMAP, let him remain in the program without prohibiting purchases or consumption of foods containing non-halal-certified meats, and stop retaliating against him for filing the action.

Harris argued that the RMAP had become a significant part of his religious exercise, that requiring him to follow Islamic dietary restrictions substantially burdened his religious practice, and that he faced irreparable harm. The defendants argued that Harris’s circumstances had not materially changed from the court’s earlier denial of similar relief and that the RMAP did not provide the GMO-free or “clean” diet Harris said his religion required.

Harris separately sought an injunction against retaliation. The court noted that the complaint challenged his inability to supplement the RMAP diet with non-halal items but did not plead a retaliation claim.

Legal standard

Under the Prison Litigation Reform Act, prospective relief concerning prison conditions must be narrowly drawn, extend no further than necessary to correct the harm requiring relief, and use the least intrusive means necessary. A party seeking a preliminary injunction must show a likelihood of success on the merits, likely irreparable harm without relief, that the balance of equities favors the party, and that an injunction would serve the public interest. The court also explained that a temporary restraining order and preliminary injunction use substantially identical standards.

Court’s analysis

The court found that Harris was unlikely to succeed on the merits of the claims supporting his request. Harris described his religious requirements as eating organic and “clean” foods and avoiding certain ingredients and processing methods. But the court found no evidence that the RMAP provided organic food or omitted the foods Harris sought to avoid. The court also noted that Harris had stated that whether meat was halal-certified was irrelevant to his Buddhist practice.

Based on that reasoning, the court concluded that removal from the RMAP would not prevent Harris from observing his religion as protected by the First Amendment’s free-exercise clause or the Religious Land Use and Institutionalized Persons Act. The court further concluded that removal had not caused irreparable harm, that the balance of equities did not favor Harris, and that the requested relief would not serve the public interest.

As to retaliation, the court held that a party is not entitled to an injunction based on claims not pleaded in the complaint. The opinion stated that Harris could amend the complaint or file a separate action if he wished to challenge alleged retaliatory conduct, but the court did not grant an injunction on that basis.

Disposition

The court granted nunc pro tunc Harris’s request for an extension of time to file his reply, meaning the court treated the filing as timely despite granting the extension after the relevant deadline. The court denied Harris’s renewed request for a temporary restraining order and preliminary injunction requiring re-enrollment in the RMAP and forbidding retaliation. The order terminated docket entries 39 and 41.