Full Breakdown
Supreme Court Denies Rastafarian Inmate’s Lawsuit Over Forced Shaving
6/23/2026, 9:29:03 PM
Core Event and Claim
In 2020, Damon Landor, a devout Rastafarian serving the final weeks of a five-month drug-possession sentence at Louisiana’s Raymond Laborde Correctional Center, presented guards with a 2017 Fifth Circuit ruling that required accommodation of his dreadlocks. Guards tossed the ruling, handcuffed him to a chair, and shaved his knee-length hair. Landor sued the Louisiana Department of Corrections and the individual guards under the Religious Land Use and Institutionalized Persons Act (RLUIPA). Lower courts dismissed the suit; the Supreme Court ruled 6-3 that RLUIPA does not allow damages against individual officials.
Background & Timeline
RLUIPA, enacted in 2000, bars burdens on prisoners’ religious exercise without a compelling governmental interest. A 2017 Fifth Circuit decision found Louisiana’s grooming policy violated the statute. In 2020, the Court allowed damages under the Religious Freedom Restoration Act for federal officials, a precedent the majority distinguished. Timeline: 2017 – Fifth Circuit rules breach; 2020 – Landor’s forced shaving and panel condemns treatment but upholds dismissal; 2024 – Landor petitions the Court; June 23 2026 – Court issues 6-3 decision rejecting damages claim.
Court Opinions & Official Responses
Justice Neil Gorsuch wrote that RLUIPA operates under the Spending Clause; individual officers are not parties to the federal-state funding contract and thus cannot be sued for monetary relief. The Justice Department, which supported Landor, argued the statute should permit enforcement against officials who violate prisoners’ religious rights. In dissent, Justice Ketanji Brown Jackson warned the ruling leaves prisoners “remediless” and mischaracterizes RLUIPA as a contract rather than a federal law.
Impact, Criticism & Opposition
The 6-3 decision narrows RLUIPA’s reach, limiting suits by prisoners and reducing incentives for prison officials to follow federal religious-rights statutes. Landor’s sentence was five months, with three weeks remaining; his dreadlocks were knee-length, grown over two decades. Two prior prisons had allowed his hair. Critics, Rachel Laser of Americans United, call the ruling hypocritical for favoring Christian claims while trampling non-Christian faiths. Justice Jackson’s dissent warns of frequent encroachments on statutory rights.
Verbatim Quotes
- “Mr. Landor does not have a federal RLUIPA cause of action against the officers,” — Justice Neil Gorsuch
- “Prisoners like Landor who suffer violations of their religious freedom in state prisons – no matter how blatant – will often be left remediless,” — Justice Ketanji Brown Jackson
- “My locks are a part of me and part of who I am,” — Damon Landor
- “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
What’s Next
Louisiana’s revised grooming policy aims to avoid similar disputes, while advocacy groups push for congressional clarification of RLUIPA’s scope and for courts to recognize a right to injunctive relief for religious-rights violations.
