Supreme Court Blocks Damages Claim After Rastafarian Man’s Hair Was Shaved in Prison

The U.S. Supreme Court ruled Tuesday that Louisiana prison officers cannot be sued personally for money damages under a federal religious liberty law by a Rastafarian man who says they forcibly shaved his head in violation of his faith.

In a six-to-three decision, the Court affirmed a ruling by the U.S. Court of Appeals for the Fifth Circuit and held that Damon Landor’s claim under the Religious Land Use and Institutionalized Persons Act (RLUIPA) cannot proceed against individual state employees.

Justice Neil Gorsuch wrote the majority opinion, joined by Chief Justice John Roberts and Justices Clarence Thomas, Samuel Alito, Brett Kavanaugh, and Amy Coney Barrett.

Landor, a Rastafarian, claims his religious beliefs require him to leave his hair uncut. According to the Court’s opinion, he spent several months in Louisiana custody in 2020 and gave intake officers a copy of a Fifth Circuit ruling that had held RLUIPA generally barred prisons from cutting Rastafarian inmates’ hair. His lawsuit claims officers threw the document away and shaved his head.

His lawsuit named the Louisiana Department of Corrections and Public Safety, along with prison officials, and sought money damages under RLUIPA. By the time the case reached the Supreme Court, only the damages claim against the individual officers remained at issue.

RLUIPA was passed in 2000 to protect religious exercise in prisons, jails, and certain land use disputes. In custody, the law bars prisons that receive federal funds from placing a substantial burden on sincere religious practice unless officials have a strong reason and use a narrow approach. The statute carries particular weight behind bars, where officials control meals, clothing, grooming, prayer schedules, and religious items.

Landor’s allegations concerned those protections, but the Supreme Court did not decide whether the shaving violated the law.

The decision turned on what remedy Congress may create when a statute is tied to federal funding. The majority treated RLUIPA as similar to a contract because the law applies to state prison systems through conditions attached to federal money. Gorsuch wrote that the Spending Clause lets Congress place conditions on those funds, but does not give Congress a general power to regulate conduct.

Louisiana’s prison system accepted federal funds and agreed to answer some claims under the religious liberty law. The justices said the individual officers were not parties to that agreement. Because they had not personally consented to face damages claims under RLUIPA, the majority held that Landor could not seek that remedy from them.

Gorsuch’s opinion left RLUIPA’s prison protections in place while narrowing one damages remedy under the statute. The Court also did not decide whether RLUIPA ever allows money damages, saying it needed to answer only whether Congress could impose damages liability on nonconsenting state employees through a statute based on the Spending Clause.

The majority rejected Landor’s argument that the officers were covered by the prison system’s funding agreement because they worked for the Louisiana agency that accepted federal funds. Gorsuch also rejected the claim that the officers indirectly received federal money through their paychecks, writing that the theory would allow Congress to regulate people whenever federal money passed through an employer, school, hospital, or other funded entity.

Justice Ketanji Brown Jackson dissented, joined by Justices Sonia Sotomayor and Elena Kagan. Jackson said RLUIPA was enacted as a federal law, not a private contract, and argued that prisoners should be able to sue employees who violate its protections.

Her dissent said the majority left prisoners with a right that may be difficult to enforce after a violation has already occurred. Jackson warned that serious religious liberty violations in state custody may often go without damages under RLUIPA.

The Supreme Court affirmed the Fifth Circuit’s judgment, leaving in place the dismissal of Landor’s federal RLUIPA damages claim against the individual Louisiana prison officers.