A Louisiana inmate who spent more than two decades growing his dreadlocks as a sacred expression of his Rastafari faith cannot sue the prison guards who forcibly shaved them off, the Supreme Court ruled Monday in a 6-3 decision that split cleanly along ideological lines.
The case of Damon Landor posed a sharp question: when a federal statute protects a prisoner's religious practice, and state officials violate that protection in defiance of a court order, can the prisoner hold the individual officers financially accountable? Six justices said no. Three said the answer guts the statute's purpose.
Landor, a Rastafarian, had grown his dreadlocks to knee length over more than 20 years. The practice holds deep religious meaning within the Rastafari tradition. When he entered Louisiana's correctional system, he obtained a court ruling specifically protecting his right to maintain his hair as a religious exercise, the Associated Press reported.
In 2020, guards at a Louisiana correctional center shaved Landor's dreadlocks anyway. He sued the individual officers under the Religious Land Use and Institutionalized Persons Act, the federal law known as RLUIPA, which Congress passed to shield incarcerated people from unnecessary government burdens on religious exercise.
The question that reached the Supreme Court was not whether the guards violated Landor's rights. It was whether RLUIPA gives prisoners the legal tool to collect money damages from the officials who did it.
Justice Neil Gorsuch, writing for the majority, held that RLUIPA does not authorize lawsuits for money damages against individual prison officials. The law applies to state institutions that accept federal funding, Gorsuch reasoned, but individual guards never personally consented to the kind of federal liability that would expose them to damage claims. As Newsmax reported, Gorsuch framed the issue in contractual terms.
"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 majority opinion drew a firm boundary: nothing in RLUIPA dealing with prisoners' religious rights authorizes lawsuits against individual officers. All six Republican-appointed justices joined the opinion. Chief Justice Roberts and Justices Thomas, Alito, Kavanaugh, and Barrett signed on alongside Gorsuch.
The ruling follows a pattern of closely divided decisions this term. The Court also split 6-3 when it reinstated the Pedro Hernandez murder conviction in the Etan Patz case, overruling the Second Circuit with the same ideological alignment.
Landor's legal team and dozens of supporting religious organizations pointed to what seemed like a strong precedent. In 2020, the Supreme Court decided Tanzin v. Tanvir, holding that the Religious Freedom Restoration Act, known as RFRA, does authorize money damages against federal officials who violate religious liberty. RLUIPA and RFRA contain identical operative language. Courts have historically interpreted the two statutes in lockstep, National Review noted in its coverage of the case's path through the lower courts.
Dozens of religious groups and leading legal scholars filed briefs supporting Landor, signaling broad concern across faith communities about what a loss would mean for prisoners' religious protections.
The majority, however, distinguished the two statutes. RFRA governs the federal government's own conduct. RLUIPA operates through the spending power, conditioning federal dollars on states' agreement to respect inmates' religious exercise. That structural difference, Gorsuch concluded, means individual state employees stand in a different legal position than federal officers under RFRA.
Justice Ketanji Brown Jackson authored a forceful dissent joined by Justices Sotomayor and Kagan. She accused the majority of transforming a binding federal statute into something closer to a voluntary arrangement.
"Today's decision magically transforms a federal statute into an invitation to be accepted or declined, deemed binding only if each particular defendant has explicitly agreed to be penalized. No matter that laws, as opposed to contracts, don't ordinarily work this way."
Jackson devoted 29 pages to her argument, calling the majority's reasoning a fundamental misread of how spending-clause legislation functions, the Washington Examiner reported. She warned that the ruling trivializes congressional power and reduces landmark federal laws to mere contractual dealings.
Her dissent went further, casting the practical consequences in blunt terms.
"Prisoners like Landor who suffer violations of their religious freedom in state prisons, no matter how blatant, will often be left remediless."
Jackson also framed Landor's case as a textbook example of why Congress passed RLUIPA in the first place. She wrote that it is rare for a real-life incident to so clearly illustrate Congress's reasons for adopting legislation.
The sharp ideological split mirrors other recent divisions on the bench. The Court split 5-4 in a separate case blocking federal courts from reviewing state cases before final judgment, another ruling that drew attention to the justices' competing views on federal power and state sovereignty.
The practical fallout is significant. RLUIPA has been the primary federal tool prisoners use to challenge religious-rights violations in state facilities. The statute covers everything from dietary restrictions to grooming practices to access to worship services. Monday's ruling does not eliminate RLUIPA's protections, but it removes one of the strongest enforcement mechanisms: the threat that an individual officer could pay out of pocket for violating an inmate's faith.
Without that financial deterrent, critics of the decision argue, prison officials face little personal consequence for ignoring religious accommodations, even when courts have already ordered those accommodations. As National Review's Bobby Miller wrote before the ruling, "Without damages as a deterrent, prison officials would continue tossing judicial precedent aside and violating the religious-liberty statute with impunity."
Prisoners may still seek injunctive relief under RLUIPA, meaning a court order directing officials to stop the violation. But for someone like Landor, whose dreadlocks were already shaved, an injunction cannot undo the harm. The hair is gone. The only remedy that could address a completed violation is money damages, and Monday's ruling closes that door against individual officers.
The decision does not address whether prisoners might pursue other legal avenues, such as claims under 42 U.S.C. Section 1983 or state tort law. Authorities have not publicly indicated whether Landor intends to pursue alternative claims.
The case created an unusual dynamic. Religious liberty is typically a priority for conservative legal organizations, and the broad coalition of faith groups backing Landor included voices from across the political spectrum. Yet the six conservative justices ruled against the prisoner, prioritizing a structural reading of federal spending power over the enforcement concern that animated the dissent.
For the three liberal justices, the case was straightforward: Congress wrote a law to protect prisoners' religious exercise, officials violated it brazenly, and the majority just told future violators they face no personal financial risk for doing it again. The Washington Times reported that the dissent's tone reflected genuine frustration with the majority's framework.
For the majority, the question was narrower. RLUIPA's text, read through the lens of spending-clause doctrine, simply does not impose personal liability on state employees who never individually agreed to it. Gorsuch wrote plainly: "Mr. Landor does not have a federal RLUIPA cause of action against the officers."
The Court has handled several high-profile cases this term with direct political implications. It handed Second Amendment groups a unanimous win when it struck down the gun ban on marijuana users, a decision that drew praise from the same conservative legal circles now grappling with Monday's religious liberty outcome.
Monday's decision will shape how religious liberty claims play out in every state prison system that receives federal funding. It will also influence how lower courts handle the growing number of RLUIPA cases involving Muslim, Jewish, Native American, and Christian inmates who challenge grooming policies, dietary rules, and worship restrictions.
The ruling does not say Landor's rights were respected. It says the law he relied on does not let him collect damages from the people who violated them.
In a term packed with consequential rulings, including the Court's decision siding with Maryland over a woman who fought involuntary psychiatric commitment, this case may prove one of the most quietly consequential for the day-to-day reality of incarcerated Americans' religious lives.
When a court order protecting a man's faith can be ignored by guards with scissors and no personal financial consequence follows, the question is no longer whether the right exists on paper. It is whether anyone behind bars can count on it meaning anything at all.
