The US Supreme Court rejected a Rastafarian prisoner's bid to sue Louisiana corrections officials for holding him down and shaving his head in 2020, a 6-3 decision that narrows the reach of a major federal law protecting religious rights in prisons.
Damon Landor had spent more than 20 years growing his hair in accordance with Rastafari tradition, which mandates uncut dreadlocks as an integral part of the faith. Near the end of a five-month drug possession sentence, he was transferred to Raymond Laborde correctional center in Cottonport, Louisiana. When he informed staff of a prior federal appeals court ruling that found Louisiana's hair-cutting policy violated his religious freedoms, a guard discarded the court document. Guards then handcuffed him to a chair and shaved his head bald.
Landor's lawsuit rested on the Religious Land Use and Institutionalized Persons Act (RLUIPA), a 2000 federal law designed to shield incarcerated people from religious discrimination. But the high court concluded the statute does not permit him to sue individual prison officials and guards for monetary damages.
Justice Neil Gorsuch, writing for the 6-3 majority, reasoned that Congress lacked the constitutional authority under the Spending Clause to impose direct liability on state officials through RLUIPA. The comparison he offered: absent an explicit agreement, state officials cannot be sued any more than a defendant can be held liable for breach of a contract they never signed.
The decision effectively means Landor has no remedy despite what his lawyers argued was a clear violation of his rights. Without the ability to recover damages, they contended, there exists no meaningful deterrent to prevent future abuses by prison staff.
Justice Ketanji Brown Jackson dissented, joined by Justices Sonia Sotomayor and Elena Kagan. She warned that prisoners like Landor who suffer blatant religious violations in state facilities will often be left without recourse, and that state prison officials now face minimal incentive to comply with federal protections.
The case arrives at a moment when the Supreme Court has expanded religious liberty in multiple recent opinions. The Trump administration sided with Landor, urging the court to revive his lawsuit. The court heard arguments in November before delivering Tuesday's ruling.
A 2017 federal appeals court had already determined that Louisiana's blanket hair-cutting policy violated RLUIPA protections. That precedent failed to stop the guards at Cottonport from proceeding with the shaving. Landor said the experience felt like violation. He initially won dismissal of his case at the district court level, upheld on appeal in 2023, and the Supreme Court's decision now closes that door entirely.
Author James Rodriguez: "This ruling leaves an open wound in religious protections for the incarcerated, and state prisons know it."
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