Maurice Lydell Harris is a California state prisoner who identifies as a Nichiren Buddhist. As a Nichiren Buddhist, Harris believes that he must follow a clean diet. The clean diet includes “‘not highly processed,’ ‘organic,’ ‘not artificial or synthetic,’ ‘described as natural,’ and which do not ‘have a chemical-sounding name.’” While the prison did not have a specific diet program for his specific religion, he enrolled in the halal prison diet, as he believed that this was the program that most closely aligned with his religious beliefs. The prison diet that Harris chose was called the Religious Meat Alternative Program (RMAP). However, the prison removed him from the diet plan when he “purchased non-halal items from the prison commissary.” Harris argued that his First Amendment Free Exercise Clause and Religious Land Use and Institutionalized Persons Act (RLUIPA) rights were violated, so he filed suit.
The RMAP diet that Harris enrolled in had specific requirements for its participants. It required that they not purchase any food that is not part of their religious diets, but are allowed to eat those foods if the RMAP meals are unavailable for whatever reason. California argues that these rules must be enforced strictly because, if they aren’t, it opens the door to people who enroll in the program insincerely, simply because they prefer the food to the normal diet plan. It also costs more than the normal meal plans, so the prison wants to make sure that every member of the diet is sincere.
In 2018, the prison changed the ingredients of the RMAP, replacing “halal meat with vegetarian options.” Harris said that he felt malnourished, and his doctor told him to increase the amount of calories and protein he was eating. Harris also had an irregular heartbeat, and all of these factors led him to buy non-halal products. He bought non-halal items such as “beef and chicken flavored instant ramen soups, pork rinds, beef steaks, and salami.” All of these are highly processed foods, which violate the halal diet. In 2019, Harris received his first warning and continued to get warnings all the way through 2022. Harris argued that the ramen products were a “staple in Nichiren Buddhist culture.” In 2023, Harris received more violations and was eventually cut from the RMAP. Harris filed for a preliminary injunction but was denied by the district court.
The primary issue the Ninth Circuit had to decide was whether Harris's beliefs were sincere. The decision first went through the lower court, in which the Ninth Circuit Court argued that they made a poor decision as they “erroneously dictated the content of Harris’s beliefs and questioned the centrality of those beliefs.” The lower court agreed with the prison and decided to affirm the decision to cut Harris from the RMAP. The Ninth Circuit Court decided to review the decision made by the district court because it believed that there could be a case of abuse of discretion. The Court argued that neither the district court nor the prison “inquired into the sincerity of Harris’s beliefs, only their centrality to his religion.” The Ninth Circuit vacated and remanded the decision, meaning that the decision made by the district court would be nullified and the Ninth Circuit would send it back to the district court for a correct ruling, making sure they look at all of the factors.
Harris argued that denying him access to the RMAP was a substantial burden on his religious exercise. He argued that prison forced him to choose between following a diet that partially followed his religious beliefs, and following that diet, but breaking the rules of the diet to buy other foods he believed were important to him, following his religion. He is essentially saying that he will either have to sacrifice his religious beliefs or his health. The Court argued that Harris is requesting to be reenrolled in RMAP while allowing him to purchase other goods that also follow his religious beliefs. He is not asking for a separate meal plan; he is just asking to be able to accommodate himself while still following the basic dietary guidelines of the RMAP.
A relevant precedent is O’lone v Estate of Shabazz(1987) because it deals with prisoners' religious rights. Two prisoners, Ahmad Uthman Shabazz and Sadr-Ud-Din Nafis Mateen, were Muslim inmates at New Jersey’s Leesburg State Prison and were denied the opportunity to go to their weekly religious service on Fridays. They were denied because of their classification within the prison and were forced to work during the weekly service. They sued the prison, arguing that their Free Exercise rights had been violated. The Third Circuit Court agreed with the inmates, arguing that the prison was required to seek alternatives and present proof that there were no other reasonable alternatives. The Supreme Court overturned its decision, arguing that the prison had a compelling interest in keeping order within the prison. They also concluded that being held in a prison places necessary limitations on inmates' rights, and they felt that to keep order within the prison, a necessary burden had to be placed on the inmates' rights.
In my opinion, I agree with Harris’s argument. The prison does not have a plan that follows Harris’s specific religion, so he was forced to join the RMAP, which only partially followed his religious beliefs. The RMAP also switched out the protein from the halal meat to vegetarian options, which had an impact on the health of Harris. The doctor said that he needed to consume more protein, which made Harris need to buy non-halal foods to make up for the protein he was missing. Not only was there a substantial burden on his religious beliefs when he was removed from the program, but there were also significant health concerns. The health concerns were a result of the RMAP changing the ingredients, and there were no records of Harris violating the RMAP before 2017-2018, because he was getting the protein he needed. He also claims that the foods he bought did not violate his specific religious diet, even if they violated the RMAP guidelines. There isn’t enough of a compelling interest from the prison or the state to deny Harris access to the RMAP, with the ability to purchase products that violate the RMAP. All of the prisoners in that specific diet program already follow it because it is their specific religion. Harris is not Muslim, but it is the best option that fits his Nichiren Buddhist religious beliefs. He should be reenrolled in the RMAP with the exemption, unless the court determines that he is insincere in his religious beliefs.
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