The Supreme Court ruled 6-3 that a former Louisiana inmate whose dreadlocks were forcibly shaved off by prison guards cannot sue those officials for money damages under federal religious-liberty law, a decision that drew a sharp dissent warning that state employees now face little consequence for trampling inmates' faith.
Damon Landor, a Rastafari practitioner, had his head shaved to the scalp during the final three weeks of a five-month prison term in 2020. He carried a copy of an appeals court ruling that said cutting religious prisoners' dreadlocks violated the Religious Land Use and Institutionalized Persons Act, known as RLUIPA. A guard at Raymond Laborde Correctional Center in Cottonport, Louisiana, roughly 80 miles northwest of Baton Rouge, took that ruling from Landor and threw it in the trash, Newsmax reported.
The warden then ordered guards to cut Landor's dreadlocks. Two guards restrained him while a third shaved his head.
Justice Neil Gorsuch wrote for the six-justice majority:
"Nothing in the law dealing with prisoners' religious rights authorizes lawsuits against individual officers."
The court declined to extend the reasoning from its 2020 decision that allowed Muslim men to sue over their inclusion on the FBI's no-fly list under a related statute, the Religious Freedom Restoration Act. Lower courts, "without exception," had already concluded that RLUIPA could not be used to hold individual violators financially responsible. The 5th U.S. Circuit Court of Appeals dismissed Landor's case on the same ground, though it lamented his treatment.
The distinction matters because RLUIPA and RFRA are separate statutes with different scopes. RLUIPA targets land-use and prison regulations. RFRA applies more broadly to federal action. The majority treated the textual differences as dispositive, whatever remedies Congress built into RFRA, it did not replicate them in RLUIPA.
The ruling lands during a packed June decision season in which the justices have been working through a heavy docket of consequential cases.
Justice Ketanji Brown Jackson, joined by two liberal colleagues whose names were not specified, pushed back forcefully. She wrote:
"It is not often that a real-life incident so clearly illustrates Congress's reasons for adopting legislation, or the Constitution's wisdom in enabling it."
Jackson argued that without the threat of personal liability, state prison officials will have little incentive to follow federal law protecting inmates' religious exercise. The dissent framed the case as a textbook example of the abuse Congress intended RLUIPA to prevent.
The disagreement echoes a broader pattern this term. The Court has split 6-3 on several high-profile matters, including a recent decision that restored a murder conviction in the Etan Patz disappearance.
Landor served a five-month prison term in 2020. At his first two stops in the Louisiana prison system, officials respected his Rastafari beliefs and left his dreadlocks alone. Then he was transferred to Raymond Laborde Correctional Center for the final three weeks of his sentence.
Court records paint a blunt picture of what happened next. Landor presented the appeals court ruling he had been carrying, a decision from another inmate's case holding that cutting religious prisoners' dreadlocks violated RLUIPA. A guard confiscated the document and discarded it. The warden ordered the haircut anyway. Guards held Landor down and shaved him.
After his release, Landor sued the prison officials. Every court that reviewed his claim agreed the conduct was wrong. None gave him a remedy.
In an unusual alignment, the Justice Department backed Landor's position. That stance marked a reversal from the department's posture during President Donald Trump's first administration, when it argued against the plaintiffs in the 2020 no-fly list case under RFRA.
The shift did not sway the majority. The Court's textualist approach treated the question as a matter of statutory construction, not policy preference. If Congress wanted RLUIPA to authorize individual-capacity damages suits, Gorsuch's opinion suggested, Congress could say so.
Louisiana, for its part, told the Court in a written filing that "the state has amended its prison grooming policy to ensure that nothing like petitioner's alleged experience can occur." The state did not detail what specific changes it made.
The case arrives as the Court nears several other major rulings on birthright citizenship, immigration enforcement, and the independence of federal agencies.
The practical effect is straightforward. Inmates whose religious rights are violated under RLUIPA can seek injunctive relief, a court order telling officials to stop, but they cannot recover money damages from the individuals responsible. For someone like Landor, who was already out of prison by the time the case reached the courts, an injunction is worthless. The harm is done.
That gap is exactly what Jackson's dissent targeted. If the only remedy available expires the moment an inmate walks out the door, then short-term prisoners, or those nearing release, have the least protection precisely when officials have the least reason to comply.
Congress passed RLUIPA with broad bipartisan support. The law was meant to give teeth to religious-exercise protections inside prisons and in local zoning disputes. Whether those teeth still bite after this ruling depends on whom you ask.
The Rastafari faith, rooted in 1930s Jamaica, treats dreadlocks as a sacred covenant. Bob Marley and Peter Tosh carried the tradition to a global audience in the 1970s. For Landor, the forced shaving was not a grooming dispute. It was an act against his faith, carried out by state employees who ignored a federal court ruling, literally tossing it in the garbage.
The Court has also been active on other fronts this term, including a unanimous decision striking down a federal firearms ban tied to marijuana use.
Several details remain unresolved. The names of the guards and warden involved were not disclosed. The specific damages Landor sought were not identified. And Louisiana's vague assurance that it fixed its grooming policy came without public detail about what, exactly, changed.
Whether Congress will act to close the remedial gap is another open question. Some Democrats have already floated structural changes to the Court itself. Senator Raphael Warnock, for instance, has called on his party to consider expanding the Court and imposing term limits, a proposal that predates this ruling but will likely gain new talking points from it.
The conservative majority read the statute as written. That is what textualism demands. But the facts of this case, a guard trashing a court order, a warden ignoring federal law, officers pinning a man down and shaving his head weeks before his release, sit uncomfortably alongside a ruling that says nobody owes him a dime.
Conservatives rightly defend religious liberty. They rightly insist that courts read statutes as Congress wrote them. This case puts those two commitments in tension. The law, as interpreted, leaves a man whose faith was violated by state force with no financial remedy and no recourse.
If Congress meant RLUIPA to protect prisoners' religious exercise, it should make sure the law actually does, with consequences that officials can feel, not just read about in opinions they apparently throw away.
