A deeply contested dispute over religious freedom behind prison walls reached its conclusion at the U.S. Supreme Court, where a divided bench ruled that a Louisiana Rastafarian inmate cannot seek monetary damages from prison staff who forcibly shaved his hair despite his religious objections.
In a 6-3 decision, the court determined that Damon Landor’s lawsuit against individual prison employees could not move forward under the Religious Land Use and Institutionalized Persons Act (RLUIPA), a federal statute designed to protect the religious rights of people confined in institutions such as prisons and jails.
Landor, whose Rastafarian faith requires him to allow his hair to grow naturally, had spent two decades cultivating locks that stretched to his knees. In 2020, while serving the final weeks of a five-month sentence for drug possession, he was transferred to the Raymond Laborde Correctional Center in Louisiana.
According to court records, Landor informed prison officials that a federal appeals court had previously ruled Louisiana’s policy of cutting Rastafarian inmates’ hair unlawful under RLUIPA. He even presented a copy of that ruling. The warning went unheeded.
What followed became the centerpiece of the legal battle. Landor alleged that officers handcuffed him to a chair, restrained him and shaved his head, erasing years of hair growth and, he argued, violating a core tenet of his faith.
The Supreme Court’s majority concluded that while RLUIPA imposes obligations on states and government entities that accept federal funding, it does not automatically expose individual employees to personal liability for damages. Writing for the court, Justice Neil Gorsuch reasoned that the law’s foundation in Congress’s spending powers means its conditions apply to the recipients of federal funds, not to employees unless they have expressly agreed to such liability.
Because the prison officials themselves were not parties to any funding agreement, the majority found that Landor could not pursue compensation from them under the statute.
The court’s liberal wing strongly disagreed.
Justice Ketanji Brown Jackson, joined by Justices Sonia Sotomayor and Elena Kagan, argued that the ruling strips many incarcerated people of an effective remedy when their religious rights are violated. In her dissent, Jackson criticized the majority’s interpretation, contending that a federal law should not be treated as though it were merely a contract requiring individual acceptance before enforcement.
The decision drew criticism from religious-liberty advocates, who warned that it weakens protections for prisoners belonging to minority faiths. Supporters of Landor argued that without the possibility of damages, prison officials may face little deterrent against future violations.
Louisiana officials welcomed the outcome, while maintaining that steps had been taken to prevent similar incidents from occurring again.
Landor, meanwhile, signaled that the legal setback would not end his pursuit of accountability. Through his legal team, he said the episode violated both his faith and personal dignity, adding that no one should endure similar treatment.
The case also highlighted a contrast in the Supreme Court’s religious-liberty jurisprudence. Landor’s attorneys had pointed to a previous ruling that allowed damages claims under the Religious Freedom Restoration Act, a separate federal law protecting religious exercise from actions by the federal government. The court, however, declined to extend a similar pathway under RLUIPA.
With the ruling, Landor’s challenge comes to a close, but the broader debate over how religious rights are protected inside America’s prisons is likely to continue.
