LOUISIANA — The Supreme Court ruled 6 to 3 that a former Louisiana inmate cannot sue state prison officials for shaving his dreadlocks. The ruling held that the Religious Land Use and Institutionalized Persons Act (RLUIPA) does not permit damages claims against individual officers.

Former Louisiana inmate Damon Landor, a Rastafarian, sued state and prison officials for violations of the RLUIPA after prison guards shaved his head. The Supreme Court's decision upheld a ruling from the U.S. Court of Appeals for the 5th Circuit.

Justice Neil Gorsuch authored the majority opinion. He stated that Landor does not have a federal RLUIPA cause of action against the officers. Gorsuch noted that under the Spending Clause, Congress lacks the regulatory authority to impose liability on them directly and must depend instead on consent. He added, "And because they never agreed to answer suits like this one, 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."

The three liberal justices dissented. Louisiana stated that the state has amended its prison grooming policy to ensure that nothing like the petitioner's alleged experience can occur.

The case, Landor v. Louisiana Department of Corrections and Public Safety, arose in 2020. Landor had nearly completed a five-month prison sentence and had upheld the Nazarite Vow for nearly 20 years, pledging to let the locks of his hair grow. For the first four months of his incarceration, two prisons permitted him to keep his hair long or under a rastacap.

Landor was transferred to the Raymond Laborde Correctional Center in Cottonport, Louisiana, for the remaining three weeks of his sentence. He told an intake guard at the facility that he was a practicing Rastafarian and provided the guard with proof of his religious accommodations. Landor gave the guard a copy of a 2017 ruling from the U.S. Court of Appeals for the 5th Circuit that found Louisiana's policy of cutting the hair of incarcerated Rastafarians violated the RLUIPA.

Prison guards threw the decision in the trash. The warden ordered guards to cut Landor's dreadlocks. Prison records indicate two guards restrained Landor while a third shaved his head to the scalp. The Justice Department sided with Landor in the Supreme Court case.

A federal judge dismissed Landor's case, finding that the RLUIPA does not allow for damages against individual state officials. A three-judge panel of the 5th Circuit upheld the dismissal, stating that a 2009 decision in the circuit ended Landor's case. The 2009 ruling held that the RLUIPA does not permit lawsuits against officers in their individual capacities. The full 5th Circuit declined to rehear Landor's case.