Supreme Court: Rastafari Man Cannot Sue Over Dreadlocks
WASHINGTON — The U.S. Supreme Court ruled on Tuesday that a former Louisiana inmate cannot sue prison officials for money damages after they forcibly shaved his dreadlocks in violation of his Rastafari religious beliefs, delivering a significant blow to the enforcement of religious freedom protections for incarcerated individuals.
In a 6-3 decision along ideological lines, the Court held that the Religious Land Use and Institutionalized Persons Act (RLUIPA) — a federal law passed unanimously by Congress in 2000 to protect the religious rights of prisoners — does not authorize lawsuits for monetary damages against individual prison officials. The ruling, authored by Justice Neil Gorsuch, affirmed lower court decisions that had dismissed Damon Landor’s lawsuit.
What Happened to Damon Landor
The case stems from an incident in December 2020, when Landor, a devout Rastafarian who had grown his hair for nearly 20 years as part of a Nazirite vow rooted in his faith, was transferred to the Raymond Laborde Correctional Center in Cottonport, Louisiana, for the final three weeks of a five-month sentence on a drug-related charge.
At two previous prisons during his incarceration, Landor had been permitted to keep his hair long or wear a “rastacap.” When he arrived at the new facility, he presented an intake guard with a copy of a binding 2017 ruling from the U.S. Court of Appeals for the 5th Circuit that held cutting Rastafarians’ hair violated RLUIPA. According to court records, the guard threw the ruling in the trash, called the warden, and Landor was handcuffed to a chair while guards shaved his head to the scalp.
“My locks are a part of me and part of who I am,” Landor told USA Today. “So when they cut off my hair, they cut off my crown.”
The Supreme Court’s Reasoning
Justice Gorsuch, writing for the majority, explained that because RLUIPA was enacted under Congress’s Spending Clause power — which allows Congress to attach conditions to federal funds — only those who “voluntarily and knowingly” consent to those conditions can be bound by them. While the Louisiana Department of Corrections accepted federal funds and agreed to comply with RLUIPA, individual prison officials never personally consented to being sued for damages.
“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,” Gorsuch wrote, as reported by AP News.
Gorsuch warned that accepting Landor’s argument would give Congress “an effectively unbridled police power,” potentially allowing it to regulate coaches at universities receiving federal funds or doctors at practices accepting Medicare.
The Dissent: A ‘Sleight of Hand’
Justice Ketanji Brown Jackson authored a sharp dissent, joined by Justices Sonia Sotomayor and Elena Kagan. Jackson argued that the majority’s decision “eviscerated” RLUIPA’s enforcement mechanism, leaving prisoners with religious rights violations “remediless.”
“This severance of rights and remedies is a sleight of hand; it comes by way of the majority’s full-throated endorsement of a contract analogy even though what secures the rights at issue is not a contract but a law,” Jackson wrote, according to SCOTUSblog.
She warned that without the threat of personal liability, “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.”
A Rare Religious Liberty Loss
The decision marks an unusual outcome from a Supreme Court that has been increasingly protective of religious rights in recent years, with many high-profile wins for conservative Christians. The Court declined to apply the rationale from its 2020 decision in Tanzin v. Tanvir, which allowed Muslim men to sue FBI agents for damages under a similar statute, the Religious Freedom Restoration Act.
The NBC News reported that the ruling “saw the conservative majority depart from its regular support for religious claims.”
Broader Implications
The decision significantly limits the ability of incarcerated individuals to seek monetary compensation for religious freedom violations in state prisons. Prisoners may still seek injunctive relief — court orders to stop ongoing violations — but cannot recover damages for harm already suffered.
Legal experts suggest the ruling may have implications beyond RLUIPA, potentially limiting Congress’s ability to attach conditions to federal funds that create personal liability for state employees.
What’s Next
Landor expressed disappointment but resolve. “What happened to me violated my faith and my dignity,” he said in a statement. “I will continue pursuing accountability. What happened to me should not happen to anyone else.”
His attorney, Zack Tripp, noted that “Congress could also take action to amend the law to ensure that prisoners whose religious rights are violated are able to obtain damages,” as reported by CBS News.
Louisiana Attorney General Liz Murrill condemned the conduct against Landor but expressed gratitude that the Court agreed with the state’s legal position. The state has since amended its prison grooming policy to prevent similar incidents.
The question now is whether Congress will act to close the enforcement gap the Court has created — or whether prisoners like Landor will be left without a meaningful remedy when their religious rights are violated behind bars.