Supreme Court Limits Damages Suits Under Prison Religious-Freedom Law
The Supreme Court ruled 6-3 on Tuesday, June 23, 2026, that a Rastafarian ex-inmate cannot sue state prison officers for money damages under the Religious Land Use and Institutionalized Persons Act in Landor v. Louisiana Department of Corrections and Public Safety.[1]
Justice Neil Gorsuch wrote the majority opinion.[2] The court held that under the Spending Clause Congress cannot impose individual-capacity liability on state officers under RLUIPA without a state's consent, and the Louisiana officers never agreed to answer those suits.[2]
In 2020 Damon Landor said he was transferred to Raymond Laborde Correctional Center where guards discarded his paperwork and forcibly shaved his knee-length dreadlocks.[1] He had carried a 2017 legal opinion recognizing Rastafarian hair accommodations and said he had kept dreadlocks under a Nazarite vow for nearly 20 years.[1] Both a district court and a Fifth Circuit panel strongly condemned the treatment.[1] They nonetheless dismissed his damages claims because they concluded RLUIPA does not authorize money suits against state officials in their individual capacities.[1]
The Supreme Court's ruling affirms those dismissals and leaves Landor without an individual-capacity money remedy under RLUIPA.[1] Observers called the outcome a rare loss for a religious-rights claimant and a departure from recent decisions that had expanded religious protections.[2]
The mainstream summary does not address the implications of the Supreme Court's ruling in the context of previous decisions regarding religious freedom. Notably, RLUIPA's language mirrors that of the Religious Freedom Restoration Act (RFRA), which the Supreme Court previously interpreted to allow individual-capacity damages in Tanzin v. Tanvir (2020). This contrast highlights a significant shift in judicial interpretation that the summary overlooks, as the ruling in Landor v. Louisiana suggests a narrowing of remedies for religious rights claimants, particularly for minority faiths like Rastafarianism, which raises broader questions about the equitable application of religious protections.[3]
Moreover, while the summary notes the ruling as a loss for religious-rights claimants, it does not capture the nuanced reactions on social media that emphasize the ruling's implications for minority faiths and the clarity of RLUIPA's provisions. Observers on platforms like BlueSky have pointed out that the decision, while narrowly focused on remedies, does not endorse the prison's actions, indicating a complex landscape of religious rights that the mainstream account fails to fully explore. This lack of detail may lead readers to underestimate the ruling's potential impact on future cases involving religious freedoms in prison settings.
Show source details & analysis (4 sources)
📊 Relevant Data
RLUIPA's remedial provision authorizes 'appropriate relief against a government,' language identical to that in the Religious Freedom Restoration Act (RFRA), under which the Supreme Court held in Tanzin v. Tanvir (2020) that individual-capacity money damages suits against officials are available.
Identical, Not Fraternal Twins: RLUIPA, RFRA, and Damages — Virginia Law Review
📌 Key Facts
- On Tuesday, June 23, 2026, the Supreme Court decided 6-3 in Landor v. Louisiana Department of Corrections and Public Safety, with Justice Neil Gorsuch writing the majority opinion and the three liberal justices dissenting (Landor v. Louisiana Department of Corrections and Public Safety).
- The Court held that, under the Spending Clause, Congress cannot impose individual‑capacity liability on state officers under the Religious Land Use and Institutionalized Persons Act (RLUIPA) without the states’ consent, and the Louisiana officers in this case never agreed to answer such suits (Spending Clause).
- Justice Neil Gorsuch’s majority opinion emphasized that the Spending Clause does not permit money damages suits against state officials in their individual capacities and contrasted that rule with the Religious Freedom Restoration Act (RFRA), which the Court previously held can allow damages against federal officials (Justice Neil Gorsuch’s majority opinion).
- The case arose after Damon Landor, a devout Rastafarian who had maintained knee‑length dreadlocks under a Nazarite vow for nearly 20 years and carried a 2017 legal opinion recognizing hair accommodations, was transferred in 2020 to Raymond Laborde Correctional Center where guards allegedly threw away his documentation, handcuffed him to a chair and forcibly shaved his head (Damon Landor).
- Both the district court and a Fifth Circuit panel “emphatically” condemned Landor’s treatment but dismissed his claims on the ground that RLUIPA does not permit money damages against individual state officials; the Fifth Circuit declined rehearing and several judges urged the Supreme Court to resolve the statutory question (Fifth Circuit).
- The Supreme Court’s ruling affirmed the judgment that bars money‑damages suits against the individual Louisiana prison officers in this case, leaving Landor without an individual‑capacity remedy under RLUIPA (RLUIPA).
- The outcome was described as a rare loss for a religious‑rights claimant at the Court and a departure from a recent string of decisions that had expanded religious‑rights protections, including earlier wins for a Texas death‑row inmate and a public high‑school coach (religious‑rights claimant).
📰 Source Timeline (4)
Follow how coverage of this story developed over time
- PBS/AP article reiterates that on Tuesday, June 23, 2026, the Supreme Court barred former Louisiana inmate Damon Landor from suing prison officials for money damages over the forced cutting of his dreadlocks.
- The article confirms the Court declined to extend its 2020 reasoning under the Religious Freedom Restoration Act (RFRA) to allow money-damages suits under the related Religious Land Use and Institutionalized Persons Act (RLUIPA).
- It details that when Landor arrived at Raymond Laborde Correctional Center for the last three weeks of his five‑month sentence in 2020, a guard threw away the appellate ruling he carried recognizing Rastafarian hair rights before the warden ordered officers to shave his head to the scalp while two guards restrained him.
- Louisiana informed the courts that it has amended its prison grooming policy to ensure similar incidents cannot occur, a remedial policy change highlighted in the filing.
- The story notes that the Justice Department, which had previously opposed plaintiffs in the analogous RFRA "no‑fly list" case under the first Trump administration, sided with Landor in this RLUIPA case.
- On Tuesday, June 23, 2026, the Supreme Court ruled 6-3 that a Rastafarian inmate whose dreadlocks were forcibly shaved cannot sue individual Louisiana prison officers for money damages under RLUIPA.
- Justice Neil Gorsuch’s majority opinion emphasized that the Spending Clause statute does not permit suits for money against state officials in their individual capacities, distinguishing it from the Religious Freedom Restoration Act (RFRA), which the Court in 2020 held does allow such damages against federal officials.
- The article highlights that the ruling represents a departure from a recent string of Supreme Court decisions expanding religious-rights protections, citing earlier wins for a Texas death-row inmate’s execution-chamber rights and a public high school football coach’s on-field prayers.
- The piece recounts additional factual detail about Damon Landor’s case: he had maintained knee-length dreadlocks for nearly 20 years under a Nazarite vow, carried a 2017 legal opinion recognizing Rastafarian hair accommodations, and alleges a guard threw that opinion in the trash before officers handcuffed him to a chair and shaved his head.
- The Fifth Circuit, while saying it "emphatically" condemned Landor’s treatment and previously upholding dreadlock protections for Rastafarian prisoners, concluded its precedent barred individual-capacity damages suits under RLUIPA and declined rehearing; nine judges urged the Supreme Court to clarify the statutory question.
- On Tuesday, June 23, 2026, the Supreme Court split 6-3 along ideological lines in Landor v. Louisiana Department of Corrections and Public Safety, with Justice Neil Gorsuch writing the majority opinion and the three liberal justices dissenting.
- The Court held that, under the Spending Clause, Congress lacks authority to impose individual-capacity liability on state officers under RLUIPA without their consent, and that Louisiana officers in this case never agreed to answer such suits.
- The article recounts specific facts of Damon Landor's case: he is a devout Rastafarian who had worn dreadlocks under a Nazarite vow for nearly 20 years, was allowed to keep them at two Louisiana prisons, then was transferred in 2020 to Raymond Laborde Correctional Center where guards threw away documentation of prior religious accommodations, handcuffed him to a chair, and shaved his head despite a 2017 Fifth Circuit precedent condemning that policy.
- The piece notes that both the district court and a Fifth Circuit panel "emphatically" condemned Landor's treatment but dismissed his claims on the ground that RLUIPA does not allow money damages against individual state officials, and that the Supreme Court's ruling affirms that judgment.
- CBS characterizes the outcome as a rare loss for a religious-rights claimant at the Supreme Court, contrasting it with a 2022 decision allowing a Texas inmate to have his pastor pray aloud and lay hands on him during execution.