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Supreme Court Blocks Rastafarian Prisoner’s Lawsuit Over Forced Head-Shaving

The U.S. Supreme Court has blocked a lawsuit brought by a Rastafarian man who said Louisiana prison officials violated his religious rights when guards forcibly shaved his head after he had grown his hair for more than 20 years.

In a 6-3 decision, the court ruled that Damon Landor could not sue individual prison officials for monetary damages under the federal law he relied on, the Religious Land Use and Institutionalized Persons Act, known as RLUIPA.

The law was passed in 2000 to protect religious exercise in land-use disputes and in institutions such as prisons and jails. Landor argued that the law should allow him to seek damages from individual officials who allegedly violated his rights. The Supreme Court disagreed, upholding lower court rulings that dismissed his case.

Landor is a devout follower of the Rastafari faith, which treats uncut hair and dreadlocks as an important religious practice. He had grown his hair for more than two decades, with locks that reportedly reached his knees.

The incident happened in 2020, near the end of a five-month sentence for drug possession, after Landor was transferred to the Raymond Laborde Correctional Center in Cottonport, Louisiana. According to court documents, Landor told prison officials that an earlier federal appeals court ruling had found Louisiana’s policy of cutting Rastafarian prisoners’ hair violated RLUIPA. He also allegedly handed officials a copy of that ruling.

Landor said a guard threw the document away. He was then handcuffed to a chair, held down and shaved bald, despite his religious objections.

Landor later sued prison officials, arguing that the forced shaving violated federal religious freedom protections. His lawyers warned that if prisoners cannot seek damages in such cases, officials may have little incentive to follow the law, especially after a violation has already occurred and the prisoner has no practical way to undo the harm.

The Trump administration backed Landor at the Supreme Court, urging the justices to revive his case. The case drew attention because the court has issued several decisions in recent years expanding protections for religious individuals and institutions.

But the majority ruled that RLUIPA does not permit Landor to sue individual officers for money damages. Justice Neil Gorsuch wrote the opinion, joined by Chief Justice John Roberts and Justices Clarence Thomas, Samuel Alito, Brett Kavanaugh and Amy Coney Barrett.

Gorsuch wrote that because RLUIPA was passed under Congress’s Spending Clause authority, it works more like a funding condition accepted by states, not as a direct personal liability rule for individual officers. He said the officers had not personally agreed to be sued for damages under the statute.

The court’s three liberal justices dissented. Justice Ketanji Brown Jackson, joined by Justices Sonia Sotomayor and Elena Kagan, warned that the ruling could leave prisoners without a meaningful remedy even when religious violations are clear.

Jackson argued that prisoners who suffer violations of their religious freedom in state prisons may now often be left with no effective way to seek accountability. She also warned that prison officials could have less incentive to respect federal religious protections if damages are unavailable.

The case also drew comparison to a 2020 Supreme Court decision under a different federal religious freedom law, the Religious Freedom Restoration Act. In that case, the court allowed damages claims against federal officials accused of violating religious rights. But the majority said the legal framework for RLUIPA is different because it applies to state institutions through federal funding conditions.

The ruling does not say that Landor’s religious rights were not violated. Instead, it focuses on what type of legal remedy Congress authorized under the statute.

Why It Matters

The decision narrows the ability of people in state prisons to seek money damages from individual officials for alleged religious freedom violations under RLUIPA. For prisoners, religious practice is often tightly controlled by institutional rules, and the ruling may make it harder to hold officials personally accountable after a violation occurs.

What Comes Next

Congress could amend RLUIPA if lawmakers want to clearly allow damages claims against individual state prison officials. In the meantime, prisoners may still seek some forms of relief under the law, but the Supreme Court’s ruling limits one of the strongest tools for accountability after alleged violations have already happened.

A legal report said the Supreme Court ruled that the prisoner could not seek monetary damages from individual prison officials under the federal religious freedom law.

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