Supreme Court bars Rastafarian inmate from suing guards who forcibly shaved his dreadlocks

The ruling

A 6-3 Supreme Court, with all conservative justices in the majority and the three liberal justices dissenting, held that the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA) cannot be used to sue individual state officials for money damages. Justice Neil Gorsuch wrote the majority opinion, finding that the statute applies to institutions, not to government agents in their personal capacity.

What happened in 2020

Damon Landor, a Rastafarian man, had grown his hair into long locks reaching his knees over 20 years. Near the end of a five-month sentence for drug possession, he arrived at the Raymond Laborde Correctional Center in Cottonport, Louisiana. He carried a copy of a federal appeals court ruling that explicitly said cutting a Rastafarian prisoner’s hair violated RLUIPA, a guard threw the document in the trash, the warden ordered the haircut, and guards handcuffed Landor to a chair and shaved him bald.

Legal path and arguments

Lower federal courts dismissed Landor’s lawsuit for damages. The 5th Circuit, while condemning the treatment, agreed that RLUIPA does not create personal liability for money damages. Landor’s lawyers argued that without a damages remedy the law would offer no deterrent, and they likened RLUIPA to the Religious Freedom Restoration Act, under which the Supreme Court in 2020 allowed Muslim men to sue over the no-fly list. The Trump administration supported Landor and urged the Court to revive the case. Louisiana said it has since amended its prison grooming policy to prevent a repeat.

Broader context

The decision contrasts with a series of recent Supreme Court rulings that expanded religious rights. Here the justices declined to read a damages remedy into the statute, leaving inmates without a path to seek compensation from individual officials even when religious rights are violated.