The US Supreme Court on Tuesday refused to allow a Rastafarian man to sue Louisiana prison officials after guards forcibly shaved his head, violating his religious beliefs. The 6-3 decision upheld a lower court's dismissal of Damon Landor's lawsuit, finding that the Religious Land Use and Institutionalized Persons Act (RLUIPA) does not permit monetary damages claims against individual prison employees.
Case Background and Religious Significance
Damon Landor, a devout Rastafarian, had grown his hair for over 20 years into long dreadlocks reaching his knees, as required by his faith. In 2020, near the end of a five-month drug possession sentence, he was transferred to Raymond Laborde Correctional Center in Cottonport, Louisiana. Despite Landor presenting a 2017 Fifth Circuit ruling that struck down Louisiana's policy of cutting Rastafarian hair, a guard discarded the document. Landor was then handcuffed to a chair, held down, and shaved bald. Landor described the experience as feeling "like I was raped."
Legal Framework and Supreme Court Ruling
RLUIPA prohibits religious discrimination by state and local governments in land-use and protects institutionalized persons' religious rights. The Supreme Court held that Congress lacked authority under the Spending Clause to impose direct liability on state officers for damages. Justice Neil Gorsuch, writing for the majority, stated that Landor "does not have a federal RLUIPA cause of action against the officers" because they never consented to such suits. Chief Justice John Roberts and Justices Clarence Thomas, Samuel Alito, Brett Kavanaugh, and Amy Coney Barrett concurred.
Dissenting Opinion and Implications
Justice Ketanji Brown Jackson, joined by Justices Sonia Sotomayor and Elena Kagan, dissented. Jackson argued that prisoners like Landor "who suffer violations of their religious freedom in state prisons – no matter how blatant – will often be left remediless" and that such rulings encourage state officials to ignore federal law. Landor's lawyers had emphasized that without a damages remedy, RLUIPA provides no deterrent against abuse.
Broader Context and Previous Rulings
The Trump administration had supported Landor, urging the court to revive the case. In 2020, the Supreme Court allowed monetary damages under the Religious Freedom Restoration Act in a similar case involving Muslim Americans placed on a no-fly list. The current ruling highlights ongoing tensions between federal religious protections and state sovereign immunity.
