The Supreme Court ruled Tuesday that a Louisiana prison inmate cannot sue the guards who forcibly shaved his dreadlocks in violation of his Rastafarian faith, limiting the remedies available under a federal religious freedom law that applies to state prisons.
The 6-3 decision, dividing the justices along ideological lines, departs from the court’s recent pattern of siding with religious liberty claims, but the majority held that the Religious Land Use and Institutionalized Persons Act does not allow individuals to sue state prison employees for monetary damages.
Damon Landor was serving a five-month sentence on a drug-related charge in 2020. For the first four months, he was allowed to keep his dreadlocks, which he had not cut for nearly 20 years and which reached to his knees, according to court records. Growing uncut, uncombed hair into dreadlocks is a symbol of devotion and spiritual growth for Rastafarians.
When Landor was transferred to Raymond Laborde Correctional Center in Cottonport, Louisiana, for the final month of his sentence, guards told him to remove his dreadlocks. Landor told a guard he was Rastafarian and handed over a copy of a 2017 federal appeals court ruling that barred Louisiana from cutting the hair of Rastafarians. The guards threw the papers in the trash, handcuffed him to a chair and shaved his head bald, court records show.
In a statement, Landor said his dreadlocks are “a part of me and part of who I am.” So when they cut off my hair, they cut off my crown,” he said.”
Landor sued the guards and other prison officials under RLUIPA, which Congress passed in 2000 to protect prisoners’ religious exercise in state institutions that receive federal funding. A federal judge and the 5th U.S. Circuit Court of Appeals ruled against him, concluding the law does not authorize lawsuits for damages against individual officers.
Justice Neil Gorsuch wrote the majority opinion, joined by the five other Republican-appointed justices. He wrote that RLUIPA operates as a contract between the federal government and states: in exchange for accepting federal funds, states agree to protect prisoners’ religious exercise. But that agreement, Gorsuch wrote, does not authorize lawsuits for money against individual officers.
“Under the Spending Clause, Congress lacks regulatory authority to impose liability on them directly and must depend instead on consent,” Gorsuch wrote. The Trump administration had filed a brief supporting Landor’s position, but the court declined to reinstate his lawsuit.
In dissent, Justice Ketanji Brown Jackson, joined by the two other Democratic-appointed justices, wrote that the ruling undermines RLUIPA’s purpose to “ensure that state and local prisons respect prisoners’ right to religious exercise.” She said that “prisoners like Landor who suffer violations of their religious freedom in state prisons — no matter how blatant — will often be left remediless.” Brown added that “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.”
Rachel Laser, president and CEO of Americans United for Separation of Church and State, criticized the ruling. “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,” she said.
The ruling marks a departure from a series of recent Supreme Court decisions in which the justices have generally sided with religious-liberty claims. Lower courts tossed out Landor’s lawsuit before the Supreme Court, and the justices on Tuesday affirmed that outcome.