The Ninth Circuit Court of Appeals vacated a district court's denial of a preliminary injunction and remanded for further proceedings in a case involving a California state prisoner's religious dietary rights. The ruling, filed Feb. 4, 2026, addresses the intersection of First Amendment protections and the Religious Land Use and Institutionalized Persons Act (RLUIPA) in the prison context.
Maurice Lydell Harris, a Nichiren Buddhist serving time in a California state prison, brought the action seeking a diet consistent with his religious beliefs. Harris asserted a sincere religious belief in the need to eat cleanly and enrolled in the halal prison diet program as the option he believed most closely aligned with his religious requirements.
The case, *Harris v. Muhammad* (9th Cir. 2026), arose after prison officials disenrolled Harris from the religious diet program. The disenrollment occurred after Harris purchased non-halal items from the prison commissary, leading officials to question the sincerity of his religious dietary requirements.
Harris challenged the prison's decision, alleging violations of both his First Amendment rights and RLUIPA. The Religious Land Use and Institutionalized Persons Act provides enhanced protections for prisoners' religious exercise, requiring that any substantial burden on religious practice be justified by a compelling government interest and implemented through the least restrictive means.
The U.S. District Court for the Northern District of California, with Judge Haywood S. Gilliam Jr. presiding, initially denied Harris's request for a preliminary injunction. However, the Ninth Circuit found significant errors in the district court's analysis of Harris's religious liberty claims.
The three-judge panel, consisting of Circuit Judges David F. Hamilton, Ryan D. Nelson, and Patrick J. Bumatay, issued an opinion authored by Judge Nelson. Judge Hamilton, a judge from the Seventh Circuit, sat by designation on the panel.
According to the appeals court's summary, the district court "erroneously dictated the content of Harris's beliefs and questioned the centrality of those beliefs." This represents a fundamental misunderstanding of how courts should analyze religious liberty claims under both the First Amendment and RLUIPA.
Under established precedent, courts are not permitted to determine what a prisoner's religion requires or to evaluate whether particular practices are central to that faith. Instead, the inquiry focuses on whether the prisoner holds a sincere religious belief that is substantially burdened by the challenged government action.
The case highlights the complex issues that arise when prisoners seek religious accommodations that may not perfectly align with traditional understandings of their faith. Harris, as a Nichiren Buddhist, sought access to a halal diet - typically associated with Islamic dietary requirements - because he viewed it as the closest available option to meet his religious need for clean eating.
Prison officials' decision to disenroll Harris based on his commissary purchases raises questions about how institutions should evaluate the sincerity of religious beliefs. The fact that Harris purchased items that might conflict with halal requirements does not necessarily negate his sincere belief that the halal diet was the best available accommodation for his religious needs.
The Ninth Circuit's decision to vacate and remand suggests the appeals court found the district court applied an overly restrictive analysis that improperly second-guessed Harris's religious beliefs. The remand will allow the district court to reconsider the preliminary injunction request under the proper legal standard.
RLUIPA was enacted in 2000 to provide stronger protections for religious exercise in institutional settings, including prisons. The law requires that any government action imposing a substantial burden on religious exercise must serve a compelling government interest and use the least restrictive means to achieve that interest.
The defendants in the case include several prison officials involved in religious programming: Cleric Muhammad (also known as K. Fasish), Jackson (identified as a chaplain), and Charles Richey, who serves as chaplain and Community Resources Manager of the California Department of Corrections and Rehabilitation's Division of Adult Institutions Religious Programs Oversight Unit.
The case was argued and submitted Sept. 17, 2025, in San Francisco. The original lawsuit was filed in 2021 in the Northern District of California under case number 4:21-cv-00283-HSG.
The decision adds to a growing body of case law addressing prisoners' rights to religious accommodations and the proper standards courts should apply when evaluating such claims. The remand will provide the district court an opportunity to apply the correct legal framework to Harris's request for preliminary injunctive relief.
The ultimate resolution of Harris's case could have broader implications for how California's prison system accommodates the diverse religious needs of its inmate population and the standards used to evaluate the sincerity of prisoners' religious beliefs.