The US Supreme Court ruled on June 23, in a conservative majority decision, that Damon Landor, a former Rastafari inmate, cannot sue prison employees for cutting his dreadlocks, which violated his religious beliefs. The ruling was based on the Religious Land Use and Institutionalized Persons Act (RLUIPA).
Justice Neil Gorsuch, writing for the majority, did not argue that Landor's religious rights were not violated. Instead, he argued that suing prison employees was inappropriate because they had not consented to liability under RLUIPA. “Landor’s case cannot proceed against them, just as a suit for breach of contract cannot proceed against a defendant who never signed the contract,” Gorsuch wrote.
The ruling upheld a lower court decision that inmates cannot seek financial damages from individual employees, even when their rights are violated.
Landor, who served five months in prison in Louisiana in 2020, expressed disappointment but stated he would not give up. In a statement through his lawyer, he said, “What happened to me violated my faith and dignity. I will continue to pursue accountability. What happened to me should not happen to anyone else.”
According to court records, when entering the correctional facility, Landor brought a copy of a 2017 appeals court ruling that cutting a religious inmate's dreadlocks violated federal law. Initially, prison staff respected his beliefs. However, after he was transferred to the Raymond Laborde Correctional Center in Louisiana, a guard threw that document into the trash, and the prison manager subsequently ordered his hair cut. Two staff members held Landor down while a third shaved his head.
In dissent, the court's three liberal justices argued that RLUIPA is a statute, not a contract. Justice Ketanji Brown Jackson, writing for the minority, argued that this distinction is key. She contended that prison employees would have little reason to comply with legal protections for inmates if there are no consequences for their actions. “It is not often that a real-world incident so clearly illustrates why Congress passed a law, or the wisdom of the Constitution in allowing it to do so,” Jackson wrote.
