The United States Supreme Court has ruled that a Louisiana prisoner whose dreadlocks were forcibly shaved in violation of his Rastafarian faith cannot pursue damages against the individual prison officials responsible for the act.
In a 6-3 decision, the court determined that Damon Landor is not entitled to sue prison guards and administrators personally under the federal Religious Land Use and Institutionalized Persons Act (RLUIPA), despite widespread acknowledgment that his religious rights were violated.
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Landor, a practicing Rastafarian, had maintained his dreadlocks for nearly two decades as a sacred expression of his faith. While serving a five-month prison sentence in 2020, he was transferred to a Louisiana correctional facility where officers ignored his objections, restrained him, and shaved his hair. According to court records, Landor had even carried documentation from a previous legal ruling affirming the rights of Rastafarian inmates to maintain their dreadlocks, but prison officials reportedly discarded the document before forcing the haircut.
Although Louisiana authorities conceded that Landor’s treatment was improper, the legal dispute centered on whether individual state employees could be held personally liable for damages under RLUIPA. The Supreme Court’s conservative majority concluded that the law does not authorize such lawsuits against individual state officials.
Writing for the majority, Justice Neil Gorsuch noted that while a similar federal statute—the Religious Freedom Restoration Act (RFRA)- permits claims against individual federal officers, the wording of RLUIPA differs significantly and does not provide the same legal remedy against state employees.
The ruling marks a notable departure from several recent Supreme Court decisions that expanded protections for religious liberty. In previous cases, the court sided with a Texas death row inmate seeking spiritual support during execution and a high school football coach who argued for the right to pray publicly after games.
The case also produced an unusual political alignment. While Louisiana opposed Landor’s claim for monetary compensation, the administration of President Donald Trump supported his lawsuit, arguing that individuals whose religious freedoms are violated should have access to meaningful legal remedies.
The court’s three liberal justices strongly dissented. Writing on their behalf, Justice Ketanji Brown Jackson argued that Congress enacted RLUIPA precisely to address situations like Landor’s and that denying him the ability to seek damages undermines the law’s purpose.
“It is not often that a real-life incident so clearly illustrates Congress’s reasons for adopting legislation,” Jackson wrote, emphasizing that Landor’s experience represented a clear violation of religious freedom.
Despite the acknowledgment from prison authorities, the support of the federal government, and the dissenting justices’ objections, the Supreme Court’s decision effectively ends Landor’s effort to hold the individual officers accountable. The ruling leaves intact the finding that his religious rights were violated while denying him a pathway to seek personal damages from those responsible.
