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.
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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.
