The Supreme Court ruled 6-3 on Tuesday in a Rastafarian Supreme Court case, holding that Damon Landor has no remedy after Louisiana prison officials shaved his dreadlocks. Landor, a Rastafari who had kept a vow not to cut his hair for more than two decades, was serving a five-month sentence in 2020 when prison officials held him down and shaved his head.
Landor v. Louisiana Department of Corrections and Public Safety
Justice Neil Gorsuch wrote for the Court’s Republican majority in Landor v. Louisiana Department of Corrections and Public Safety. The decision turned on the way the Religious Land Use and Institutionalized Persons Act of 2000 was drafted, with Gorsuch accepting a distinction that left Landor without a damages remedy against the prison officials who acted against him.
Before the shaving, Landor brought a copy of a federal appeals court decision to the prison. That decision said Louisiana prisons could not cut the hair of Rastafari prisoners who wished to keep it long for religious reasons, but guards threw it in the trash and shaved him anyway. Ian Millhiser described the conduct as one of the most obvious violations of religious liberty imaginable, yet the Court still held that Landor could not recover from the officials who carried it out.
Rastafari hair rule in Louisiana
Landor’s hair had grown nearly long enough to reach his knees by the time of the forced shaving. The case leaves a direct gap between a stated religious-liberty protection and a remedy a prisoner can actually use after the violation has already happened.
For prisoners raising the same kind of claim, the practical lesson is narrow but clear: under this ruling, pointing to a federal religious-liberty decision was not enough to stop the shaving in Landor’s case, and it was not enough to win damages afterward. The Court gave a legal answer, but not a remedy for the head shaving itself.
