In a 6–3 decision in Landor v. Louisiana Department of Corrections and Public Safety, the Supreme Court held that Damon Landor cannot sue prison officials for money damages even after the Court found his forced haircut violated federal religious liberty law.
For Damon Landor, the punishment was not just a haircut. It was a vow broken.
Landor is a Rastafari who, for religious reasons, does not cut his hair. His lawyers say he kept that vow for more than two decades—until 2020, while he was serving a five-month sentence for a drug-related offense. Prison officials handcuffed him to a chair, held him down, and shaved his head.
Afterward, Landor was transferred to the prison where the forced shaving occurred. He brought with him a copy of a federal appeals court decision holding that Louisiana prisons violate federal religious liberty law when they cut the hair of Rastafari prisoners who wish to keep it long for religious reasons. When he presented that decision to prison guards, they threw it in the trash and shaved his head anyway.
On Tuesday, the Supreme Court handed down its decision in Landor v. Louisiana Department of Corrections and Public Safety. In a 6–3 ruling. the Republican majority held that Landor has no remedy against the prison officials who carried out the shaving—even though the Court said the officials committed one of the most obvious violations of religious liberty to reach it.
The Court’s decision lands in conflict with how the justices often treat religious-liberty claims, particularly when plaintiffs are Christian. Landor is a break from that broader pattern, and it is unclear why the Republican justices chose this case despite that departure.
One explanation offered in the legal discussion around the ruling is that Landor could undermine civil rights and public health statutes that Republicans oppose. The immediate result. regardless of motive. is stark: Landor cannot obtain money damages. and his violated rights do not translate into accountability for the individual guards who forced his haircut.
At the center of the ruling is a hypertechnical distinction about how the federal Religious Land Use and Institutionalized Persons Act of 2000—RLUIPA—was drafted. and how it could have been drafted differently. RLUIPA prohibits state prison systems that receive federal funding from imposing “substantial burden[s] on the religious exercise[s]” of state prisoners outside exceptional circumstances.
There was little doubt, in the Court’s view, that forcibly shaving Landor’s head violated RLUIPA. But Landor sued the prison officials who actually shaved his hair, seeking to hold them personally liable.
In his opinion for himself and his fellow Republicans. Justice Neil Gorsuch focused on the fact that RLUIPA does not directly regulate prisons or prison guards. Instead, it imposes conditions on states that accept federal grants. If a state or prison system takes that money. Gorsuch reasoned. it must comply with RLUIPA’s religious-liberty protections—but the logic of the statute. as written. does not automatically give individual prisoners a pathway to sue employees for money damages.
The opinion compares the structure to a contract. The state prison where Landor was incarcerated agreed to comply with RLUIPA. but Gorsuch concluded that the prison employees did not agree to be bound in the specific way needed to face personal damages suits under the law. Congress. the opinion notes. could have written RLUIPA to make that possible—such as by conditioning federal funding on officers agreeing to enter separate contracts with the federal government consenting to answer suits under RLUIPA. or by conditioning funds on Louisiana enacting a state law that permits prisoners to sue guards who violate RLUIPA.
If the federal government had a Congress willing to act quickly, the ruling suggests, the problem could be fixed.
In dissent. Justice Ketanji Brown Jackson wrote that the Court’s approach reduces to dissatisfaction with the precise way Congress structured RLUIPA. She argued that the ruling “hairsplitting undervalues Congress’s lawmaking prerogative. ” and she said “we ought not substitute our rigid contract-based preferences for Congress’s considered statutory design.”.
Yet lower courts, at least, have largely favored Gorsuch’s formalism. Many federal appeals courts have agreed that prisoners like Landor are not allowed to sue prison officials for money damages under RLUIPA. That meant. for many observers. that the Court’s outcome was not entirely unpredictable—even if the underlying facts were shocking.
The ruling is also tied to a much broader fight over abortion enforcement in emergency situations.
In the immediate aftermath of Landor, the legal reasoning Gorsuch used has been described as potentially setting up how another statute—federal emergency abortion rules—could be treated in disputes against red states.
Federal Emergency Medical Treatment and Labor Act. or EMTALA. requires hospitals that accept Medicare funding to provide “such treatment as may be required to stabilize the medical condition” of “any individual” who arrives at the emergency room with an “emergency medical condition.” EMTALA includes no exception for abortion. Under its text. the argument is that federal law unambiguously requires hospitals to provide emergency abortions when needed to stabilize an emergency medical condition. and it also says state and local laws are superseded “to the extent that the [state law] directly conflicts with a requirement of this section.”.
Idaho, however, refused to comply with EMTALA. A dispute over whether Idaho’s broad abortion ban could restrict emergency abortions reached the Supreme Court in Moyle v. United States in 2024.
In Moyle, the justices voted to dismiss the case without deciding it. But Justice Samuel Alito wrote a dissenting opinion that closely resembled the approach Gorsuch took in Landor. Alito argued that EMTALA, like RLUIPA, operates like a contract: hospitals receive federal funding and agree to provide certain procedures. But he said the state of Idaho is not a party to that agreement. in the same way that the prison guards in Landor did not agree to be bound by RLUIPA. On that view, Idaho’s broad ban should not be limited by EMTALA.
After Landor, it has been described as “fairly clear” that Alito’s position should control Moyle. The result, in practical terms, would be that lower courts may reject attempts to enforce EMTALA against red states. That could reduce pressure on the justices to directly overrule EMTALA protections themselves.
The warning attached to that chain of reasoning is grim: women in red states who need emergency abortions to save their lives could be left without legal protection.
Landor’s case is about one person’s religion and one broken vow—Rastafari hair forcibly shaved in 2020. But the Court’s decision. by treating accountability as something Congress must authorize with exacting precision. is likely to ripple far beyond a prison chair and a discarded court decision. For Landor, the bottom line is already in place. For the broader fights over rights. it is a question of whether the courts will recognize the harm—or whether the law will simply point to Congress and move on.
Supreme Court Landor v. Louisiana Department of Corrections and Public Safety Damon Landor Rastafari RLUIPA religious liberty prison officials emergency abortion EMTALA abortion ban Moyle v. United States Neil Gorsuch Ketanji Brown Jackson Samuel Alito