The United States Supreme Court ruled on Tuesday that a former Louisiana inmate cannot sue prison officials who held him down and shaved his dreadlocks, even though the court acknowledged his religious rights had been violated. In a 6-3 decision along ideological lines, the conservative majority held that the Religious Land Use and Institutionalized Persons Act (RLUIPA) — a federal law enacted in 2000 to protect the religious freedoms of incarcerated people — does not permit lawsuits for monetary damages against individual prison employees.
The case centres on Damon Landor, who served a five-month prison term in 2020 on a drug-related charge. Rastafarianism, a faith rooted in 1930s Jamaica that emerged as a response by Black people to white colonial oppression, holds uncut, uncombed hair as a symbol of devotion and spiritual growth. Aware of his rights, Landor entered the prison system carrying a copy of an appeals court ruling that explicitly found cutting a Rastafarian prisoner's dreadlocks violated federal law. For the first four months of his sentence, officials at his initial facilities respected his beliefs. But at the Raymond Laborde Correctional Center in Cottonport, a town roughly 130 kilometres northwest of Baton Rouge, a guard threw his legal documents in the trash. The facility's warden then ordered guards to cut his hair. Two officers restrained Landor in a chair while a third shaved his head to the scalp.
Writing for the majority, Justice Neil Gorsuch did not dispute that Landor's religious rights had been violated. Rather, he argued that RLUIPA — which functions under Congress's Spending Clause, placing conditions on states that accept federal funding — imposes obligations only on the state or local entity receiving those funds, not on individual employees who never personally consented to legal liability.