In Harris v. Muhammad, (9th Cir., Feb. 4, 2026), the U.S. 9th Circuit Court of Appeals vacated a California federal district court's denial of a preliminary injunction to a Buddhist inmate who had been taken off of the prison's Religious Meat Alternative Program (RAMP) because he often purchased non-Halal food from the prison commissary. Plaintiff was a Nichiren Buddhist. On advice of the prison chaplain, Harris chose RAMP, a halal compliant diet, as the closest to his Nichiren Buddhist belief that he should eat natural foods that are not highly processed. His precise diet that was unavailable did not require halal certification. The district court held that taking Harris off of RAMP was not a substantial burden on his religious exercise since his religion did not require him to limit his intake to halal meat. The 9th Circuit said in part:
By conditioning his ability to receive the diet which most aligns with his beliefs on whether he keeps Islamic dietary laws, Harris has shown a substantial burden on his religious exercise. ...
Holding otherwise imposes a judicial assessment of what diet is required by Harris’s Nichiren Buddhist faith....
Judges ought not be Pharisees, decreeing from on high what practices are relevant to a prisoner’s understanding of his own faith. See Matthew 23:23. ... And if external forces cause Harris to fall short of the exact dictates of his religion, it is for him and his conscience, not us as courts, to decide what compromises are appropriate. Thus, it is sufficient that Harris asserts that he sincerely believes that the RMAP program “is closest to his spiritual needs.” In holding that an Islamic diet is not required by Harris’s Buddhist faith, the district court erred by discounting Harris’s own understanding of his faith....
... Harris’s departures from the Islamic diet—or even a Buddhist diet—do not demonstrate that his beliefs do not require him to adhere to that diet if possible. “[A] sincere religious believer doesn’t forfeit his religious rights merely because he is not scrupulous in his observance; for where would religion be without its backsliders, penitents, and prodigal sons?” ...
Each man’s faith is his own, and judges must avoid questioning whether a prisoner has strictly abided by the letter of his own sincere belief.
The district court erred by considering these backslides as part of a centrality inquiry (i.e., concluding that expulsion from RMAP would not affect Harris’s ability to practice his own religion)....
Although courts may not determine what actions are dictated by a plaintiff’s personal religious beliefs, a court may determine whether those beliefs are sincerely held..... RLUIPA does not entitle insincere believers in the “Church of Surf ‘n’ Turf” to luxury lobster and steak dinners. But it also protects the rights of sincere believers, who may not fully adhere to their stated beliefs.
Neither the district court nor the prison inquired into the sincerity of Harris’s beliefs, only their centrality to his religion. The district court should consider that issue in the first instance....
