A man whose dreadlocks were forcibly shaved by Louisiana prison guards has lost his bid for damages at the nation's highest court. In a 6-3 ruling divided along ideological lines, the Supreme Court on Tuesday determined that Damon Landor — a devout Rastafarian who had maintained his locks for nearly two decades — has no avenue under federal law to pursue monetary claims against the individual state officers responsible.
Landor had been nearing the end of a five-month sentence in 2020 when the incident took place. His faith required him to honor the Nazarite Vow to "let the locks of the hair of his head grow," a commitment he had upheld for close to 20 years. During the first four months of his incarceration, two separate facilities allowed him to keep his hair long or covered with a "rastacap."
The situation changed dramatically in the final three weeks of his sentence, after his transfer to Raymond Laborde Correctional Center. Landor informed an intake guard of his religious practice and handed over documentation of his accommodations, including a 2017 ruling from the U.S. Court of Appeals for the 5th Circuit that had found Louisiana's hair-cutting policy toward incarcerated Rastafarians violated the Religious Land Use and Institutionalized Persons Act. According to court filings, guards discarded that ruling in a trash can, restrained Landor in a chair with handcuffs, and shaved his head.
He subsequently brought suit against the warden and guards under the RLUIPA, the federal statute shielding the religious rights of institutionalized persons. A federal district court threw out the case, concluding the law provides no damages remedy against state officials sued in their individual capacities. A 5th Circuit panel agreed, "emphatically" denouncing how Landor had been treated while nonetheless invoking a 2009 circuit precedent that foreclosed such claims. The full 5th Circuit declined to reconsider the matter.
Justice Neil Gorsuch authored the majority opinion in Landor v. Louisiana Department of Corrections and Public Safety, concluding that Landor "does not have a federal RLUIPA cause of action against the officers." Because the statute rests on Congress's Spending Clause power, the court reasoned, it operates as a form of conditional agreement rather than a direct mandate — and state officials who never consented to personal liability cannot be held to it. "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," Gorsuch wrote.
The court's three liberal justices dissented. The outcome stands as an unusual setback for a religious-rights claimant; the Supreme Court has generally favored such plaintiffs in recent terms, including a 2022 decision in favor of a Texas inmate who sought to pray during his execution. Tuesday's ruling leaves the 5th Circuit's judgment intact.
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