The Supreme Court sided with Louisiana prison officials on Tuesday, blocking a Rastafarian inmate from seeking damages after they cut off his dreadlocks against his religious objections. The 6-3 ruling turned on a technical reading of federal civil rights law rather than the underlying religious freedom question.
Damon Landor was serving a five-month drug sentence at the Raymond Laborde Correctional Center in 2020 when guards handcuffed him to a chair and shaved his head. He had maintained his dreadlocks for two decades as part of his Nazirite vow, a Rastafarian religious practice. Before the incident, he showed officers a court document stating that cutting a Rastafarian's hair would violate their religious rights. They proceeded anyway.
Landor sued under the Religious Land Use and Institutionalized Persons Act, known as RLUIPA, which covers any local prison receiving federal funding. The law is designed to protect the religious exercise of incarcerated people. But the court's conservative majority ruled that RLUIPA does not permit lawsuits against individual prison officials unless those officials had agreed in advance to face such liability.
Writing for the majority, Justice Neil Gorsuch compared the situation to a breach of contract claim. "Mr. Landor's case cannot proceed against them any more than a breach of contract action might proceed against a defendant who never formed a contract," he wrote. The decision split along ideological lines, with conservative justices in the majority and liberal justices dissenting.
In her dissent, Justice Ketanji Brown Jackson argued that the ruling gutted RLUIPA's core purpose. She noted that the law's entire foundation is ensuring state and local prisons respect prisoners' religious freedoms. By blocking damages claims, the court had made the law largely unenforceable against prison officials, she said. "Prisoners like Landor who suffer violations of their religious freedom in state prisons, no matter how blatant, will often be left remediless," Jackson wrote.
The Louisiana Department of Corrections did not contest that Landor was mistreated. State officials acknowledged in court filings that they have since changed their grooming policies to prevent similar violations affecting other Rastafarian inmates. Landor's legal team had pointed to a 2020 Supreme Court decision involving a separate civil rights law, the Religious Freedom Restoration Act, which does allow damages in certain cases. Louisiana countered that RLUIPA should not be read the same way because it applies to state and local facilities, not federal ones.
Lower courts had ruled in Louisiana's favor, prompting Landor to seek Supreme Court review. The justices' decision to affirm those rulings closed off a major avenue for inmates challenging religious rights violations in state prisons, at least on federal grounds.
Author Sarah Mitchell: "The court's refusal to let Landor pursue damages raises serious questions about how federal law actually protects religious exercise in prisons when the remedies are stripped away."
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