Supreme Court denies Rastafarian ex-inmate’s lawsuit over shaved dreadlocks

Washington — The Supreme Court on Tuesday rejected a former Louisiana inmate’s effort to sue state prison officials after they shaved his dreadlocks in violation of his religious beliefs.

The high court divided 6 to 3 along ideological lines in ruling against Damon Landor, with the three liberal justices in dissent. Justice Neil Gorsuch authored the opinion for the majority.

Landor, who is a devout Rastafarian, sought to sue the Louisiana Department of Corrections and Public Safety and prison officials for violations of the Religious Land Use and Institutionalized Persons Act, or RLUIPA, after prison guards shaved his head. While lower courts condemned Landor’s treatment, judges on two different courts dismissed his claims. The Supreme Court’s ruling upholds the decision from the U.S. Court of Appeals for the 5th Circuit rejecting Landor’s effort to revive his suit against the officers.

Landor, Gorsuch wrote, “does not have a federal RLUIPA cause of action against the officers. Under the Spending Clause, Congress lacks regulatory authority to impose liability on them directly and must depend instead on consent. And because they never agreed to answer suits like this one, 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.” 

The ruling is a rare loss for a plaintiff arguing violations of his religious rights. In recent years, the high court has repeatedly sided with religious parties, including in a 2022 decision in favor of a Texas inmate who requested his pastor lay hands on him and audibly pray during his execution.

In a dissenting opinion joined by Justices Sonia Sotomayor and Elena Kagan, Justice Ketanji Brown Jackson rejected what she said was the majority’s “full-throated endorsement of a contract analogy,” and warned its decision will leave prisoners like Landor whose suffer violations of their religious rights while incarcerated “remediless.”

“Encroachments on prisoners’ statutory rights are likely to happen with fair frequency, as 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,” Jackson wrote.

Louisiana Attorney General Liz Murrill said in response to the Supreme Court’s decision: “Religious liberty is deeply important, and Louisiana has laws on the books protecting it. Ten federal courts of appeals held that the federal Religious Land Use and Institutionalized Persons Act does not allow prisoners to sue prison officials in their personal capacities for damages, and now the Supreme Court has agreed. We condemn the conduct as alleged in this case and have taken steps to prevent this problem from recurring, but we are grateful the Court agreed with the State in this matter.”

The case, known as Landor v. Louisiana Department of Corrections and Public Safety, arose in 2020, when Landor had nearly completed a five-month prison sentence. As a devout Rastafarian, Landor pledged to “let the locks of the hair of his head grow,” known as the Nazarite Vow, which he had upheld for nearly 20 years.

For the first four months of his incarceration, two prisons had permitted Landor to keep his hair long or under a “rastacap.” But that changed after Landor was transferred to the Raymond Laborde Correctional Center for the remaining three weeks of his sentence. Landor told an intake guard at the facility that he was a practicing Rastafarian and provided the guard with proof of his religious accommodations. He also gave the guard a copy of a 2017 ruling from the U.S. Court of Appeals for the 5th Circuit, which found Louisiana’s policy of cutting the hair of incarcerated Rastafarians violated the RLUIPA, according to court papers.

But prison guards threw the decision in the trash, handcuffed Landor to a chair and shaved his head, his lawyers said.

Landor sued the prison warden and guards under the RLUIPA, which protects the religious rights of individuals confined to institutions. A federal judge dismissed the case, finding that the law does not allow for damages against individual state officials. A three-judge panel of judges on the 5th Circuit upheld that decision.

While the appeals court “emphatically” condemned Landor’s treatment, it said a 2009 decision in the circuit ended his case. In that earlier ruling, the 5th Circuit held that the RLUIPA doesn’t permit lawsuits against officers in their individual capacities. The full 5th Circuit then declined to rehear Landor’s case.

The Trump administration backed Landor in the dispute, warning in court papers that if inmates could not obtain money damages in actions against government officials sued in their individual capacities, it would undermine RLUIPA’s enforcement.