Supreme Court Rules Against Inmate Whose Dreadlocks Were Forcibly Cut

The United States Supreme Court ruled 6-3 that Damon Landor, a former inmate at a Louisiana prison, cannot seek monetary damages from individual prison officials under the Religious Land Use and Institutionalized Persons Act (RLUIPA) after his dreadlocks were forcibly cut in 2020.

The Court held that the law, enacted under Congress's Spending Clause power, does not permit lawsuits against state employees in their personal capacities because those employees did not consent to be sued.

Incident Background

In 2020, Landor was serving a five-month sentence on a drug-related charge at the Raymond Laborde Correctional Center in Louisiana.

Landor, a Rastafarian, had not cut his hair for 20 years, following a Nazirite vow. For Rastafarians, growing uncut hair into dreadlocks is a religious practice and symbol of devotion.

According to court records:

• Landor presented prison staff with a court ruling stating that cutting a Rastafarian's dreadlocks would violate religious rights.
• An intake guard reportedly discarded the document.
• The warden then requested paperwork from Landor's sentencing judge.
• When Landor could not provide it immediately, officers handcuffed him to a chair and shaved his head despite his protests.

The incident occurred approximately three weeks before his scheduled release.

Legal Proceedings

After his release, Landor filed a lawsuit under RLUIPA seeking monetary damages from the individual prison officials involved. RLUIPA applies to state and local prisons that receive federal funding.

The state of Louisiana did not contest that Landor was mistreated and stated that the prison system has since changed its grooming policy.

Lower courts had previously sided with Louisiana, ruling that RLUIPA does not allow for individual lawsuits against state employees.

Supreme Court Ruling

Justice Neil Gorsuch authored the majority opinion. The Court held that RLUIPA, enacted under Congress's Spending Clause authority, operates as a contract between the federal government and the state or local entity receiving federal funds.

Under this framework:

• The law imposes obligations only on the state or local entity, not on individual employees.
• Because the individual prison officials did not personally consent to be sued, the Court ruled that the lawsuit against them cannot proceed.

Justice Gorsuch wrote that under the Spending Clause, "Congress lacks regulatory authority to impose liability on them directly and must depend instead on consent."

Dissenting Opinion

Justice Ketanji Brown Jackson wrote a dissenting opinion, joined by the Court's two other liberal justices.

Jackson argued that the distinction between a law and a contract is key, and that the majority's contract analogy undermines congressional power.

She stated that the goal of RLUIPA was to "ensure that state and local prisons respect prisoners' right to religious exercise."

Jackson added that without consequences for violations, prison officials may not abide by legal protections for prisoners.

Statement from Damon Landor

Damon Landor expressed disappointment with the ruling.

"What happened to me violated my faith and my dignity. I will continue pursuing accountability."