Supreme Court: Rastafarian man can't sue guards over dreadlocks

The U.S. Supreme Court ruled 6-3 on Tuesday that a Rastafarian man whose dreadlocks were forcibly shaved by Louisiana prison guards cannot sue those officials for money damages under a federal religious-liberty law.

The decision, split along ideological lines with the court's conservative justices in the majority, leaves Damon Landor without a financial remedy even though no party to the case defended what was done to him. The court affirmed a ruling by the 5th U.S. Circuit Court of Appeals in Landor v. Louisiana Department of Corrections.

At issue was the Religious Land Use and Institutionalized Persons Act, or RLUIPA, which protects the religious exercise of incarcerated people by barring prisons from imposing substantial burdens on their faith without a compelling justification. As El País reported, the court did not decide whether Landor's rights were violated, only whether individual officers could be held personally liable for such a violation.

What the court decided

Writing for the majority, Justice Neil Gorsuch explained that RLUIPA, enacted under the Constitution's Spending Clause, functions much like a contract between the federal government and recipients of federal funds. Louisiana's prison system accepted those funds and thereby accepted the law's obligations, but individual employees made no such agreement.

"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.

Gorsuch warned that the alternative theory would hand Congress sweeping power. "On Mr. Landor's theory, Congress could require coaches at universities that receive federal funds to permit transgender athletes to play women's sports — or face personal liability in suits for damages," he wrote, according to Courthouse News Service.

The justices declined to extend the reasoning of their 2020 decision in Tanzin v. Tanvir, which allowed Muslim men to sue individual federal officials for damages under a sister statute, the Religious Freedom Restoration Act. Notably, the Justice Department had sided with Landor in this case.

The dissent

Justice Ketanji Brown Jackson wrote the dissent, joined by Justices Sonia Sotomayor and Elena Kagan. She argued the majority wrongly treated RLUIPA as a contract rather than a federal statute and left inmates like Landor without a remedy.

"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," Jackson wrote.

She added that the ruling reduces major civil rights laws "to nothing more than the wheelings-and-dealings of an especially wealthy private party," and warned officials would have little incentive to abide by federal protections absent consequences. Jackson also wrote that the case showed "Congress's reasons for adopting legislation, or the Constitution's wisdom in enabling it."

How the case arose

Landor served a five-month sentence in Louisiana in fall 2020. As a Rastafarian, he had not cut his hair for some 20 years, observing what followers call the Nazarite vow. Officials at his first stops respected his beliefs.

When he was transferred to the Raymond Laborde Correctional Center in Cottonport, Landor presented a printed 2017 5th Circuit ruling holding that Louisiana's policy of cutting Rastafarians' hair violated federal law. A guard threw the document in the trash, and the warden then ordered his hair cut. Two officers restrained him while a third shaved his head to the scalp, according to court records. Reports differ on whether Landor was held in lockdown for his final three weeks or had the document discarded before the warden refused him time to obtain more paperwork.

Lower courts dismissed his suit, with the 5th Circuit lamenting his treatment but concluding the law did not allow damages against the officials. The episode echoes broader tensions over religious discrimination and the limits of legal accountability, a theme also visible in the Supreme Court's recent ruling for a Mississippi death row inmate on jury bias.

Reaction

Landor vowed to keep fighting, in a statement reported by Al Jazeera. "I am disappointed but not defeated," he said through his lawyers. "What happened to me violated my faith and my dignity. I will continue pursuing accountability. What happened to me should not happen to anyone else."

Zack Tripp, a Weil Gotshal partner representing Landor, pointed to changes already prompted by the case. "Damon succeeded in generating real change, including in Louisiana, which revised its grooming policies in response to this case," Tripp said, adding that the opinion notes possibilities Congress could pursue to provide a remedy.

Louisiana Attorney General Liz Murrill condemned the officers' conduct but said the state was grateful for the court's support, noting Louisiana has separate state laws safeguarding religious liberty. Critics were sharper. "Once again, we see a court that will bend over backward for the religious freedom of Christians, but allows the government to trample the religious freedom of non-Christians," said Rachel Laser, president of Americans United for Separation of Church and State.

Frequently Asked Questions

Sources

• Al Jazeera — US Supreme Court says Rastafarian man shaved by prison guards can't sue
• Courthouse News Service — Supreme Court denies damages for Rastafarian dreadlock shaving
• El País English — Supreme Court rules that Rastafarian ex-inmate cannot sue the Louisiana prison officials who cut off his dreadlocks
• First Amendment Center — Supreme Court rules Rastafarian can't sue La. prison officials who cut his dreadlocks

Reporting compiled from court records and the cited source outlets.