The Supreme Court ruled on Tuesday that Damon Landor, a devout Rastafarian prisoner whose dreadlocks were forcibly cut in Louisiana, cannot sue prison officials for alleged violations of federal religious protections under RLUIPA. In a 6-3 decision written by
For Damon Landor, the humiliation didn’t end with the first shave.
Guards at a Louisiana prison handcuffed him to a chair and cut off the knee-length dreadlocks he had grown over nearly two decades. Minutes earlier. Landor had handed them a judicial opinion he said showed they were required to allow dreadlocks for religious purposes. The guards tossed the opinion in the trash before holding him down and cutting his hair.
Landor later tried to take his fight to court. On Tuesday, the Supreme Court ruled that he could not proceed with his case.
Justice Neil Gorsuch wrote for a 6-3 majority that prisoners cannot sue officials to enforce federal religious protections unless Congress has given explicit authority for that kind of lawsuit. The decision. the justices said. reflects the court’s hesitancy to let Americans bring claims to enforce rights without clear congressional permission.
The majority ruled that Landor couldn’t sue state officials over his treatment because those local officials were not aware of the details of the federal law that protects religion.
Justice Ketanji Brown Jackson, writing for the court’s three liberal justices, criticized the ruling as a weakening of RLUIPA’s practical power. She said the court’s move will make it far harder for prisoners to drag officials into court over alleged violations of statutory religious rights.
“Prisoners like Landor who suffer violations of their religious freedom in state prisons – no matter how blatant – will often be left remediless. ” Jackson wrote. She argued that state-empowered prison officials will have little incentive to follow federal law. even when it is “handed to them on a piece of paper.”.
At the center of the dispute was the Religious Land Use and Institutionalized Persons Act, or RLUIPA. Landor’s case began from the moment guards at a Louisiana prison forced the haircut after he was nearing the end of a five-month sentence for drug possession. He had begun serving the sentence in 2020.
Landor had previously taken a promise known as the Nazarite vow to not cut his hair. He carried a copy of an appeals court ruling from 2017 that allowed prisoners to have dreadlocks.
The Supreme Court record also describes the path Landor took through multiple facilities before arriving at the Raymond Laborde Correctional Center. He was incarcerated without incident at two other facilities before being transferred.
In 2016, Congress passed RLUIPA, along with another law dealing with religious accommodation more broadly, in response to a controversial 1990 precedent from the court. Landor argued that the law’s protections should allow him to sue.
His claim ran into a legal distinction the court ultimately embraced. In late 2020, the Supreme Court ruled that the other law—containing nearly identical language—allows people whose religious rights have been burdened to seek damages against government officials in their individual capacity.
Louisiana countered that RLUIPA is effectively a spending contract between state officials and the federal government. which provides funding for state prisons. Under that argument. the individual officials involved in Landor’s forced shaving were not parties to the contract. and therefore could not be held personally liable.
The dispute moved through appeals. A panel of the conservative 5th U.S. Circuit Court of Appeals ruled that Landor was not entitled to sue. The 5th Circuit said it “emphatically” condemned “the treatment that Landor endured. ” but added that an earlier appeals court precedent settled the case against him. The full appeals court ultimately decided against rehearing the case, and Landor appealed to the Supreme Court in 2024.
The Supreme Court’s Tuesday decision also landed in a context where many Americans expect religious-liberty cases to go differently. On the one hand, the case appeared designed for a court that, in recent years, has often sided with religious interests.
Last year. the court sided with a group of religious parents who wanted to opt their children out of books dealing with LGBTQ themes in elementary school. In 2022. it backed a high school football coach who had been removed from his job for praying on the field before games. A year before that. it allowed a Catholic foster care agency in Philadelphia to continue working for the city even though it declined to screen same-sex couples as potential foster parents.
Rachel Laser, the president and CEO of Americans United for Separation of Church and State, described the ruling as hypocritical.
“Once again, we see a court that will bend over backward for the religious freedom of Christians but allows the government to trample the religious freedom of non-Christians,” Laser said. Her organization frequently opposes decisions from the Supreme Court that back religious interests.
The ruling closes off Landor’s attempt to sue—at least on the path he chose—leaving a case that began with guards dumping an opinion into the trash to end, months later, with the Supreme Court blocking it from going forward.
Supreme Court RLUIPA Rastafarian dreadlocks Damon Landor Louisiana prison religious freedom Neil Gorsuch Ketanji Brown Jackson