Supreme Court news turned on Damon Landor’s claim that Louisiana prison officials violated his religious rights when they shaved his dreadlocks in 2020. On Tuesday, the court ruled 6-3 that he cannot seek damages under the Religious Land Use and Institutionalized Persons Act, or RLUIPA.
Landor, a devout Rastafarian former inmate, had been serving a five-month sentence on a drug-related charge when he was moved to the Raymond Laborde Correctional Center. He had not cut his hair for 20 years in accordance with the Nazirite vow, and he said officers handcuffed him to a chair and shaved his head despite his protestations.
Gorsuch on RLUIPA
Justice Neil Gorsuch wrote for the majority that RLUIPA does not allow claims against individual officials. He said, “Mr. Landor’s case cannot proceed against them any more than a breach of contract action might proceed against a defendant who never formed a contract.”
The court’s reading leaves damages unavailable in this type of suit unless the officials had consented to face liability under RLUIPA. Landor’s lawyers had asked the justices to allow damages and pointed to a 2020 ruling under the Religious Freedom Restoration Act.
Jackson on prisoners
Justice Ketanji Brown Jackson said the purpose of RLUIPA is to “ensure that state and local prisons respect prisoners’ right to religious exercise.” She added that “Prisoners like Landor who suffer violations of their religious freedom in state prisons — no matter how blatant — will often be left remediless.”
That split matters because the state did not contest that Landor was mistreated. Louisiana argued that it should not be liable for damages because RLUIPA applies to federal, not state, officials, and lower courts sided with Louisiana before Landor appealed to the justices.
Louisiana grooming policy
In court papers, Louisiana said the prison system has changed its grooming policy so other Rastafarian prisoners do not face the same situation. That leaves the practical effect of the ruling on future claims tied to whether a prisoner can seek a damages remedy under RLUIPA against the officials involved, rather than to whether the underlying religious objection is accepted.
For Landor, the ruling closes the damages path he pursued over what happened at the Raymond Laborde Correctional Center in 2020. The broader question he raised is now set by the court’s answer: under RLUIPA, that remedy does not reach the individual officials he sued.
