Supreme Court rules Rastafarian ex-inmate can't sue prison officials for shaving dreadlocks

Washington — The Supreme Court on Tuesday turned away a former Louisiana prisoner’s bid to sue state prison officials who cut off his dreadlocks despite his religious objections.

In a 6-3 decision that split the court along ideological lines, the justices ruled against Damon Landor. The court’s three liberal members dissented, while Justice Neil Gorsuch wrote the majority opinion.

Landor, a devout Rastafarian, had attempted to bring claims against the Louisiana Department of Corrections and Public Safety and prison officials under the Religious Land Use and Institutionalized Persons Act, known as RLUIPA, after guards shaved his head. Although lower courts sharply criticized what happened to him, judges in two courts dismissed his case. The Supreme Court’s decision leaves in place a ruling by the U.S. Court of Appeals for the 5th Circuit that blocked Landor from reviving his lawsuit against the officers.

Gorsuch wrote that Landor “does not have a federal RLUIPA cause of action against the officers.” He said Congress, acting under the Spending Clause, cannot directly impose liability on the officers and instead must rely on consent. Because the officers never agreed to face suits of this kind, Gorsuch wrote, Landor’s claims could not move forward “any more than a breach of contract action might proceed against a defendant who never formed a contract.”

The outcome marks an unusual defeat for a plaintiff asserting religious-rights violations before the Supreme Court. In recent years, the justices have often ruled in favor of religious claimants, including in a 2022 case involving a Texas inmate who asked that his pastor be allowed to lay hands on him and pray aloud during his execution.

Justice Ketanji Brown Jackson dissented, joined by Justices Sonia Sotomayor and Elena Kagan, criticizing the majority’s “full-throated endorsement of a contract analogy.” She warned that the ruling could leave incarcerated people like Landor with no remedy when their religious rights are violated behind bars.

“Encroachments on prisoners’ statutory rights are likely to happen with fair frequency, as state-empowered prison officials will have little incentive to abide by federal law, even if it is handed to them on a piece of paper,” Jackson wrote.

Louisiana Attorney General Liz Murrill welcomed the ruling, saying: “Religious liberty is deeply important, and Louisiana has laws on the books protecting it. Ten federal courts of appeals held that the federal Religious Land Use and Institutionalized Persons Act does not allow prisoners to sue prison officials in their personal capacities for damages, and now the Supreme Court has agreed. We condemn the conduct as alleged in this case and have taken steps to prevent this problem from recurring, but we are grateful the Court agreed with the State in this matter.”

The case, known as Landor v. Louisiana Department of Corrections and Public Safety, arose in 2020, when Landor had nearly completed a five-month prison sentence. As a devout Rastafarian, Landor pledged to “let the locks of the hair of his head grow,” known as the Nazarite Vow, which he had upheld for nearly 20 years.

For the first four months of his incarceration, two prisons had permitted Landor to keep his hair long or under a “rastacap.” But that changed after Landor was transferred to the Raymond Laborde Correctional Center for the remaining three weeks of his sentence. Landor told an intake guard at the facility that he was a practicing Rastafarian and provided the guard with proof of his religious accommodations. He also gave the guard a copy of a 2017 ruling from the U.S. Court of Appeals for the 5th Circuit, which found Louisiana’s policy of cutting the hair of incarcerated Rastafarians violated the RLUIPA, according to court papers.

But prison guards threw the decision in the trash, handcuffed Landor to a chair and shaved his head, his lawyers said.

Landor sued the prison warden and guards under the RLUIPA, which protects the religious rights of individuals confined to institutions. A federal judge dismissed the case, finding that the law does not allow for damages against individual state officials. A three-judge panel of judges on the 5th Circuit upheld that decision.

While the appeals court “emphatically” condemned Landor’s treatment, it said a 2009 decision in the circuit ended his case. In that earlier ruling, the 5th Circuit held that the RLUIPA doesn’t permit lawsuits against officers in their individual capacities. The full 5th Circuit then declined to rehear Landor’s case.

The Trump administration backed Landor in the dispute, warning in court papers that if inmates could not obtain money damages in actions against government officials sued in their individual capacities, it would undermine RLUIPA’s enforcement.

Leave a Reply

Your email address will not be published. Required fields are marked *

You May Also Like

A new chapter for America’s 250th: 'J250' initiative puts Jewish contributions in the spotlight

J250 Puts Jewish Contributions at Heart of America’s 250th

DOJ launches 15-city antisemitism awareness tour amid rising hate crimes As antisemitic…
Texas toddlers taped to their chairs at Spanish immersion daycare, company said 'makeshift seatbelts' weren't abuse

Texas Spanish Immersion Daycare Claims Toddlers Taped to Chairs With Makeshift Seatbelts Was Not Abuse

Video shown to a parent appears to show a daycare worker using…
Fmr Arizona Dem candidate accused of storming into ex's home with knife, tape, blames 'misunderstanding'

Former Arizona Democratic Candidate Accused of Entering Ex’s Home With Knife and Tape, Claims Misunderstanding

A former Democratic congressional candidate in Arizona has been arrested after police…
Chicago Mayor Brandon Johnson, City Council budget accountability coalition trade blame on projected $98 million budget shortfall

Chicago Budget Crisis: Johnson, Council Clash Over $98M Gap

CHICAGO () — Some Chicago city workers, including police officers, could be…
Convicted gun felon awaiting sentencing earned spot at Rikers World Cup watch party with Mamdani

Convicted Gun Felon at Mamdani’s Rikers World Cup Party

A Rikers Island detainee recently convicted by a jury on felony gun…
'Jeopardy!' champion Caleb Groen from Thousand Oaks, California tops $300,000 after 10 wins

Jeopardy! Champion Caleb Groen of Thousand Oaks Surpasses $300,000 With 10th Win

LOS ANGELES — Caleb Groen, a Thousand Oaks, California, native, has become…
Nolan Wells' mom opens up in heartbreaking video: 'My heart will never be whole again'

Nolan Wells’ Mom Breaks Silence in Heartbreaking Video

Nolan Wells’ grieving mother became emotional as she spoke publicly about the…
Iran calls on Houthis to prepare to cut off Red Sea gateway — can the terror group do it?

Can Iran-Backed Houthis Really Shut Down the Red Sea Gateway?

Iran threatens to close Strait of Hormuz, impacts global oil prices FOX…
Tyler Robinson's father runs thriving hometown business as taxpayers face possible $10M defense bill: report

Tyler Robinson’s Dad Runs Firm as $10M Defense Bill Looms

Inside digital evidence presented during preliminary hearing in Tyler Robinson trial New…
Department of Children and Family Services, or DCFS, Lurie Children's Hospital, Safe Kids Illinois promote Water Watcher campaign

Illinois Water Watcher Campaign Aims to Stop Child Drownings

EVANSTON, Ill. () — With summer temperatures sending families to swimming pools,…
Over 90 million Americans under severe weather threat as intense storms target the East Coast through weekend

90 Million Americans Face Severe Weather Threat as Powerful Storms Move Toward East Coast This Weekend

A round of powerful weekend storms is forecast to sweep into the…
Body pulled from San Francisco Bay after deadly boat accident near Alcatraz

Body Recovered in San Francisco Bay After Alcatraz Boat Crash

A body has been pulled from San Francisco Bay as investigators continue…