In Kane v. Haynes, (9th Cir., July 23, 2026), the U.S. 9th Circuit Court of Appeals reversed and remanded a district court's dismissal of a free exercise claim brought by a Muslim inmate against prison officials. The court said in part:
While transferring then-inmate Ali Kane between units at the Airway Heights Correctional Center, Department of Corrections (DOC) officers disposed of an unmarked Arabic-language copy of the Quran. After Kane initiated DOC’s grievance process, DOC offered Kane a replacement copy in English. Kane refused, stating that his religious practice requires him to memorize and utter his prayers in Arabic.
Kane sued the correctional officers in their official capacity under 42 U.S.C. § 1983, claiming the officers’ destruction of Kane’s copy of the Quran and refusal to provide a substitute Arabic-language copy violated his First Amendment right to free exercise....
... Kane ... offered that his inability to memorize the Arabic passages has severe religious consequences (e.g., sin cannot be forgiven as required by Islam), and Kane, having since forgotten the verses, cannot meet his daily religious obligations.
The district court, however, did not ... evaluate whether the government has shown a legitimate penological interest justifying its actions under [Turner v. Safley]... We thus remand so that the district court may consider the Turner factors....