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By Hannah Parry
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The Supreme Court's conservative majority has ruled against a Rastafarian inmate whose dreadlocks were forcibly shaved by prison officials, in a decision that could make it harder to enforce religious freedom protections for other federal prisoners.
In a 6-3 decision in Landor v. Louisiana Department of Corrections and Public Safety, the court ruled that Damon Landor cannot seek monetary damages from individual Louisiana prison officials who allegedly violated his religious rights under the Religious Land Use and Institutionalized Persons Act (RLUIPA).
The ruling presents a striking contrast with many of the court's recent religious liberty decisions, which have generally favored claimants seeking exemptions from government regulations or accommodation for religious practices.
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What To Know
Landor, a devout Rastafarian, alleges that prison officials forcibly shaved his dreadlocks in 2020 even after he informed them that his faith required him to keep his hair uncut. According to court filings, Landor carried a copy of a prior federal court ruling recognizing similar religious protections for Rastafarian prisoners, but officials allegedly ignored it.
The Supreme Court did not dispute the seriousness of the alleged violation. Instead, the case turned on a narrower legal question: whether RLUIPA allows individuals to recover money damages from state employees in their personal capacities.
Writing for the majority, conservative Justice Neil Gorsuch concluded that it does not.
Because RLUIPA operates through Congress's Spending Clause authority, the court reasoned that liability can be imposed only on parties who have voluntarily accepted the conditions attached to federal funding. Louisiana's prison system accepted those conditions, the majority said, but individual correctional officers did not. As a result, the court held that prison employees cannot be personally liable for damages under the statute.
The majority framed the issue as one of consent. Federal spending laws function much like contracts, the court said, and individuals cannot be subjected to personal liability under such laws unless they knowingly agreed to those terms.
Justice Ketanji Brown Jackson, joined by the court's other liberals, dissented. She argued that the ruling effectively leaves victims of undisputed religious-liberty violations without a meaningful remedy and undermines Congress's effort to protect religious exercise in prisons.
Human and prison rights activists have condemned today's decision, with Daniel Mach, director of the ACLU’s Program on Freedom of Religion and Belief, calling it a "devastating blow to the religious freedom and dignity of incarcerated people," in a statement on Tuesday.
"Prison officials held Damon Landor down and forcibly shaved his dreadlocks in violation of his Rastafarian faith, after throwing in the trash a copy of a binding federal court order confirming prisoners’ religious right to wear dreadlocks," he said. "By denying Mr. Landor a meaningful remedy, the Supreme Court has made it harder to hold prison officials accountable when they violate the rights of people in their custody.
“Religious freedom does not stop at the prison gate, and civil rights are real only when they can be enforced. This decision sends a dangerous message that prison officials may escape accountability even for egregious violations of federal law. The ACLU will continue fighting to ensure that incarcerated people can practice their faith, protect their bodily autonomy, and seek justice when their rights are violated.”
A Different Outcome Than Most Other Religious Liberty Cases
The decision stands out because the Supreme Court's conservative majority has repeatedly sided with religious claimants over the past decade.
During the COVID-19 pandemic, the court repeatedly sided with churches challenging public-health restrictions on religious gatherings. In Roman Catholic Diocese of Brooklyn v. Cuomo, the court blocked New York's attendance limits on houses of worship, signaling a more robust approach to protecting religious exercise.
The Supreme Court later ruled in favor of a high school football coach who prayed on the field after games in Kennedy v. Bremerton School District, holding that his religious expression was protected by the First Amendment.
In Carson v. Makin, the court held that Maine could not exclude religious schools from a tuition-assistance program available to private schools. And in Groff v. DeJoy, the court strengthened protections for employees seeking religious accommodations in the workplace.
In 2020, the court unanimously ruled in Tanzin v. Tanvir that Muslim men who were allegedly placed on the federal No Fly List because they refused to become FBI informants could seek monetary damages from federal officials under the Religious Freedom Restoration Act (RFRA).
Together, those decisions helped cement the court's reputation under Chief Justice John Roberts as one of the most religion-friendly courts in modern history.
Why Landor's Case Is Different
The key distinction, according to the majority, was not the value of religious freedom but the source of the legal remedy.
Unlike many of the Supreme Court's previous religious liberty cases, Landor involved a statute enacted under Congress's Spending Clause power. That led the court to focus on whether Congress clearly authorized personal-capacity lawsuits against state employees. The majority said no.
Critics argue that the result exposes a tension in the court's religious liberty jurisprudence. While the court has often been willing to expand protections for religious exercise, Landor limits the remedies available when those rights are violated.
Supporters of the ruling counter that the decision reflects a broader principle of judicial restraint: courts should not create damages remedies that Congress did not clearly authorize.
The ruling underscores an important legal distinction between recognizing a right and providing a remedy for its violation.
Who Is Damon Landor?
Landor is a former Louisiana inmate and a devout Rastafarian who followed a Nazarite vow associated with his faith, meaning he did not cut his hair, for almost 20 years by 2020, with some reports describing his dreadlocks as almost reaching his knees.
During a roughly six-month incarceration in Louisiana for drug possession, two correctional facilities accommodated his religious practice and allowed him to keep his hair. The dispute arose only after he was transferred to a different prison shortly before his release.
According to court filings, he carried a copy of an earlier federal court decision recognizing similar protections for Rastafarian inmates and presented it to prison staff before the shaving occurred. That guard allegedly threw away the ruling, and Landor's hair was forcibly shaved off.
Landor told ABC News that the incident had been deeply traumatic, saying: "When I was strapped down and shaved, it felt like I was raped."
He was released from prison shortly after the incident and then pursued litigation against Louisiana officials.
What Is A Rastafarian?
Rastafarianism, or Rastafari, is a religious and cultural movement that emerged in Jamaica in the 1930s. It emphasizes spiritual freedom, African heritage, and resistance to oppression. Many Rastafarians regard Haile Selassie I, the former emperor of Ethiopia, as having special spiritual significance and view Ethiopia as a symbolic homeland.
One of the most visible aspects of the faith is the wearing of dreadlocks. Many Rastafarians follow a Nazarite vow based on biblical teachings that prohibit cutting one's hair. As a result, dreadlocks are not merely a hairstyle but a religious expression of devotion, identity, and spiritual commitment.
The most internationally famous person associated with Rastafari is Bob Marley, whose music helped spread awareness of the movement around the world.
Contact Newsweek editors on this story: Gabe Whisnant and Sam Wilson.
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