The Ninth Circuit Court of Appeals issued an opinion Tuesday strengthening protections for prisoners' religious dietary accommodations, ruling that a California state prisoner's request for a halal diet based on his Buddhist beliefs must be reconsidered by a lower court.
The court vacated the U.S. District Court for the Northern District of California's denial of a preliminary injunction in *Harris v. Muhammad* (9th Cir. 2026), remanding the case for further proceedings. The decision centers on Maurice Lydell Harris, a Nichiren Buddhist who sought dietary accommodations consistent with his religious beliefs while incarcerated.
Harris asserted a sincere religious belief requiring him to eat cleanly and enrolled in the prison's halal diet program as the option he believed most closely aligned with his religious needs. The case arose when prison officials disenrolled Harris from the religious diet program after he purchased non-halal items from the prison commissary.
The prisoner challenged that decision under both the First Amendment's Free Exercise Clause and the Religious Land Use and Institutionalized Persons Act (RLUIPA), a federal law that provides heightened protections for religious exercise in institutional settings.
Judge Ryan D. Nelson, writing for the three-judge panel that included Judge David F. Hamilton of the Seventh Circuit sitting by designation and Judge Patrick J. Bumatay, held that the district court made fundamental errors in analyzing Harris's religious claims.
"The panel held that the district court erroneously dictated the content of Harris's beliefs and questioned the centrality of those beliefs," the court wrote in its summary. The appellate court found that the lower court improperly substituted its own judgment about what Harris's religious beliefs should entail rather than accepting his sincere assertions about his faith requirements.
The case highlights the complex intersection between religious accommodation and prison administration. While correctional facilities have significant authority to maintain order and security, federal law requires that they provide reasonable accommodations for prisoners' sincere religious beliefs unless doing so would pose substantial burdens on institutional operations.
Under RLUIPA, which Congress enacted in 2000, prisons must demonstrate that any substantial burden on religious exercise serves a compelling governmental interest and uses the least restrictive means possible. The law was designed to strengthen protections for religious exercise in institutional settings, including prisons and other government facilities.
The Ninth Circuit's decision suggests that courts must be careful not to second-guess the substance of an inmate's religious beliefs, even when those beliefs might appear unconventional or when the requested accommodation seems to conflict with traditional understanding of that religion. In this case, Harris's request for a halal diet as a Buddhist practitioner illustrates how individual religious expression can transcend conventional religious categories.
The court's analysis focused on the district court's improper scrutiny of Harris's beliefs rather than accepting his sincere assertion that eating cleanly was central to his Nichiren Buddhist practice. This approach aligns with Supreme Court precedent establishing that courts should not evaluate the theological correctness or centrality of religious beliefs but should instead focus on whether those beliefs are sincerely held.
The decision also raises questions about how prison systems should handle religious dietary accommodations when inmates' practices don't conform to traditional expectations. Prison officials argued that Harris's purchase of non-halal commissary items demonstrated that his dietary requirements weren't sincere, but the appellate court's reversal suggests this reasoning was flawed.
The case originated in the Northern District of California under District Judge Haywood S. Gilliam Jr., who initially denied Harris's request for a preliminary injunction. The Ninth Circuit heard oral arguments in the case on Sept. 17, 2025, in San Francisco.
The panel's decision strengthens the framework for evaluating prisoners' religious accommodation requests and emphasizes that courts must defer to inmates' sincere assertions about their religious needs rather than imposing external judgments about theological correctness.
This ruling fits within a broader pattern of federal appellate courts taking a protective stance toward prisoners' religious rights under RLUIPA. The law has generated significant litigation as inmates have sought accommodations for various religious practices, from dietary requirements to religious grooming standards.
The case now returns to the district court for further proceedings consistent with the Ninth Circuit's analysis. The lower court will need to reconsider Harris's preliminary injunction request without questioning the content or centrality of his religious beliefs, focusing instead on whether the prison's denial of accommodation serves compelling institutional interests through the least restrictive means.
The decision could have broader implications for how California's prison system and other correctional facilities handle religious dietary accommodations, particularly in cases where inmates' requests don't align with conventional religious expectations. Prison administrators will need to focus on sincere belief rather than theological orthodoxy when evaluating accommodation requests.