WASHINGTON, D.C. — The Supreme Court issued a 6-3 opinion in Landor v. Louisiana Department of Corrections on June 23, 2026, holding that lawsuits cannot be brought against individual government officials who violate the Religious Land Use and Institutionalized Persons Act unless those officials consent to being sued.

Justice Neil Gorsuch authored the majority opinion. The Court concluded that the case against the prison guards could not proceed because they had not agreed to answer suits. Gorsuch stated, "[t]o sort out whether consent exists—and thus whether a condition associated with spending legislation is enforceable—we have traditionally turned to contract principles for guidance."

Damon Landor, a Rastafarian, was imprisoned in Louisiana. His religious beliefs require him to leave his hair uncut. Prison guards in Louisiana shaved Landor's head after he provided them with a copy of a U.S. Court of Appeals for the 5th Circuit opinion, which stated that the Religious Land Use and Institutionalized Persons Act bars prisons from cutting Rastafarians' hair.

The Religious Land Use and Institutionalized Persons Act stipulates that state and local governments receiving federal funds for prisons and jails cannot infringe upon a person's religious beliefs unless such action is necessary to achieve a compelling government purpose. The Tucker Act grants the U.S. Court of Federal Claims jurisdiction over suits based on any express or implied contract with the United States.

Gorsuch also stated that allowing Congress to create civil liability for state institutions and individual actors to enforce the Religious Land Use and Institutionalized Persons Act would be "elastic enough to allow the 'extraction of money damages' from virtually anyone who violates virtually any condition found in Spending Clause legislation."