Summary
The Ninth Circuit vacated the denial of Maurice Lydell Harris’s request for a preliminary injunction concerning his access to a halal prison diet. The court held that the district court improperly questioned the centrality of Harris’s dietary beliefs to his Nichiren Buddhist faith and should instead assess whether those beliefs are sincerely held and substantially burdened under RLUIPA. The case was remanded for further proceedings, including consideration of whether prison officials can satisfy RLUIPA’s compelling-interest and least-restrictive-means requirements.
Topics
Practice areas
Questions Presented
- Whether the district court applied an impermissible centrality-based analysis when deciding whether Harris demonstrated a substantial burden on religious exercise under RLUIPA.
- Whether a prisoner's sincere belief that a religious dietary alternative best accommodates his faith can establish a substantial burden without the court determining whether that alternative is actually required or central to the prisoner's religion.
- Whether the district court's denial of a preliminary injunction should be vacated and remanded for a new analysis of substantial burden, sincerity, and the remaining preliminary-injunction factors.
Holdings
- Courts may not question the centrality of particular beliefs or practices to a faith or invalidate a prisoner's sincere interpretation of his religious obligations. The district court therefore erred by deciding that halal meat was irrelevant to Harris's Nichiren Buddhist beliefs and that removal from the program would not affect his religious observance.
- Harris sufficiently demonstrated a prima facie substantial burden by alleging that removal from RMAP forced him to choose between following what he sincerely viewed as his religious diet and incurring a prison violation and possible loss of the accommodation.
- Courts may determine whether a prisoner's asserted religious beliefs are sincerely held, but sincerity is the permissible inquiry; centrality, doctrinal correctness, and strict adherence are not.
- If Harris establishes a substantial burden, the government must prove that enforcing the regulation is in furtherance of a compelling governmental interest and is the least restrictive means of furthering that interest.
- The district court's denial of Harris's preliminary-injunction request was vacated because the court applied an erroneous centrality-based analysis.
Key quotations
“Holding otherwise imposes a judicial assessment of what diet is required by Harris’s Nichiren Buddhist faith, which is the incorrect mode of analysis.” (at 12)
“But “[i]t is not within the judicial ken to question the centrality of particular beliefs or practices to a faith, or the validity of particular litigants’ interpretations of those creeds.”” (at 13)
“In other words, sincerity is a permissible inquiry for courts to make; centrality is not.” (at 14)
“The district court erroneously dictated the content of Harris’s beliefs and questioned the centrality of those beliefs.” (at 16)
Factual background
Harris, a California state prisoner and Nichiren Buddhist, asserted a sincere religious belief in eating cleanly and enrolled in the prison's Religious Meat Alternative Program because its halal-meat diet most closely aligned with his religious needs. After prison officials found that he had purchased non-halal commissary items, including ramen, pork rinds, steaks, and salami, a review committee disenrolled him from the program. Harris alleged that losing access to the program substantially burdened his religious exercise and sought preliminary injunctive relief allowing him to remain enrolled while supplementing his diet.
Procedural history
Harris filed a pro se civil-rights complaint after receiving notices of violation for purchasing non-halal commissary food while enrolled in California's Religious Meat Alternative Program. The district court screened the complaint, allowed several constitutional and RLUIPA claims to proceed, and later denied Harris's requests for a preliminary injunction. Harris timely appealed the denial of his second request for injunctive relief.
Remand instructions
The district court must conduct a new analysis of whether Harris has shown a substantial burden on his religious exercise, including a permissible inquiry into whether his beliefs are sincerely held rather than an inquiry into their centrality. The court should ensure that Article III standing exists and allow any reasonable amendment to name the proper defendant. If Harris establishes a substantial burden, the court must apply RLUIPA's compelling-interest and least-restrictive-means standard and then reconsider the remaining preliminary-injunction factors.