The U.S. Supreme Court ruled Tuesday that a Louisiana inmate whose dreadlocks were forcibly shaved by prison guards cannot pursue a lawsuit seeking monetary damages from individual state employees. In a 6-3 decision, the court held that federal law does not authorize prisoners to sue state prison officials in their personal capacities for violations of religious rights under the Religious Land Use and Institutionalized Persons Act (RLUIPA).
Damon Landor, a Rastafarian, had sued guards and the warden after they shaved his dreadlocks without consent during his incarceration. Landor, who had not cut his hair for nearly 20 years in accordance with his faith, was serving a five-month sentence for drug possession. Four months into his term in 2020, after being transferred to a new facility, guards forcibly shaved his long dreadlocks. Landor had brought with him a 2017 legal opinion affirming that prisoners must be allowed to keep dreadlocks under RLUIPA, but a guard reportedly discarded the document before the haircut occurred.
The statute requires state and local prisons receiving federal funds to accommodate prisoners’ sincerely held religious beliefs and allows those whose rights are violated to seek “appropriate relief.” However, the Supreme Court majority, led by Justice Neil M. Gorsuch, reasoned that the law does not extend to individual state employees because such officials do not themselves receive federal funds or expressly agree to financial obligations linked to federal grants. Gorsuch warned that broadening liability could expose employees in federally funded institutions—such as university coaches or physicians—to personal lawsuits based on compliance with federal directives.
The court’s ruling contrasts with a 2020 decision that allowed individuals to sue federal officials personally under a related law, the Religious Freedom Restoration Act (RFRA). The justices were divided over whether RLUIPA should be interpreted similarly. The dissenters—Justices Ketanji Brown Jackson, Sonia Sotomayor, and Elena Kagan—argued that Congress intended to hold state officials accountable for religious rights violations and that the refusal to permit lawsuits against such officials would leave prisoners without meaningful remedies. Jackson warned that the ruling diminishes incentives for prison staff to uphold federal protections for religious freedom.
Landor expressed disappointment following the decision, stating that what happened to him violated his faith and dignity and “should not happen to anyone else.” Lawyers for Landor and supporters of religious freedom criticized the ruling as a setback that leaves inmates vulnerable to abuses without financial recourse. Zack Tripp, one of Landor’s attorneys, said the decision forecloses damages claims against officials who violate inmates’ religious rights but noted that Congress could potentially amend the law to provide a remedy.
The legal battle had previously seen the U.S. Court of Appeals for the Fifth Circuit affirm legal protections for Rastafarian prisoners’ dreadlocks yet decline to permit lawsuits against state officials based on binding precedent. The full Fifth Circuit refused to rehear the case but called on the Supreme Court for guidance on this complex issue. Advocacy groups have warned that the ruling hampers accountability for religious rights violations within the prison system.
