Rastafarian man can’t sue prison guards who shaved him bald, US Supreme Court says

The US Supreme Court refused on Tuesday to let a Rastafarian man sue state prison officials in Louisiana after guards held him down and shaved him bald in violation of his religious beliefs in a case brought under a federal law protecting incarcerated people from religious discrimination.
The Supreme Court, in a 6-3 ruling powered by its conservative majority, upheld a lower court’s decision to dismiss Damon Landor’s lawsuit, agreeing that he could not sue the individual prison officials and guards for monetary damages under the statute at issue.
Landor’s religion ‌requires him to let his hair grow.
“I am disappointed but not defeated,” Landor said in a statement provided by 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.”
The Supreme Court’s three liberal justices dissented from the ruling, which was written by conservative Justice Neil Gorsuch.
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
Rachel Laser, advocacy group CEO
The law at issue, called the Religious Land Use and Institutionalised Persons Act of 2000, or RLUIPA, prohibits religious discrimination by state and local governments in land-use regulations and also protects the religious rights of people confined to institutions such as prisons and jails.
The court ruled that because RLUIPA implicates the power of Congress under the Constitution’s so-called Spending Clause, the measure may impose conditions only on the state or government entity that is ⁠the actual recipient of federal funds, not individual employees who do not themselves receive the funds – unless they consent.
Since the prison officials never agreed that they would be subject to lawsuits under RLUIPA, “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 said.
Liberal Justice Ketanji Brown Jackson, writing in dissent, noted that RLUIPA is a law, not a contract.
“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 penalised,” said Jackson, joined by Justices Sonia Sotomayor and Elena Kagan.
US President Donald Trump’s administration had backed Landor, urging the Supreme Court to ⁠revive his lawsuit.
“We condemn the conduct as ⁠alleged in this case and have taken steps to prevent this problem from recurring, but we are grateful the court agreed with the state in this matter,” Republican Louisiana Attorney General Liz Murrill said in a statement.

Rachel Laser, president and CEO of the advocacy ‌group Americans United for Separation of Church and State, said the ruling endangers the religious freedom of incarcerated people like Landor who are especially vulnerable to abuse.
“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,” Laser said.
In important religious rights cases in recent years, the Supreme Court often has sided with Christian plaintiffs.
Zack Tripp, a lawyer for Landor, expressed disappointment in the ruling, saying that “inmates ‌whose religious rights are violated by state prison officials will have no damages remedy no matter how egregious the wrong”.
Landor grew his hair over a span of 20 years into long locks that reached his knees. ⁠In 2020, near the end of a five-month prison sentence for drug possession, Landor was transferred to the Raymond Laborde Correctional Centre in Cottonport, Louisiana.
There, Landor reminded officials that the New Orleans-based 5th US Circuit Court ⁠of Appeals had ruled in a 2017 case that Louisiana’s policy of cutting the hair of Rastafarians violated RLUIPA.
Landor even handed over a copy of that ruling, but a guard threw it in the trash, according to court documents.
Landor was then handcuffed to a chair, held down and shaved.

Landor, who lives in Slidell, Louisiana, sued, but a judge threw out his case. In ‌2023, the 5th Circuit upheld that decision.
In her dissent, Jackson ‌said prisoners who experience religious freedom violations will now often be left without a remedy.
“And encroachments on prisoners’ statutory rights are likely to happen with fair frequency, as state-empowered prison officials will have little incentive to abide by federal law, even if it is handed to them on a piece of paper,” Jackson said.
Landor’s lawyers have called RLUIPA similar to a 1993 law called the Religious Freedom Restoration Act that prohibits religious infringement by the US government.
In 2020, the Supreme Court allowed for monetary damages claims under the Religious Freedom Restoration Act in a case involving three Muslim US citizens who sought to sue FBI agents who they accused of placing the men on the government’s “no-fly list” for refusing to become informants.