Court Narrows Religious Freedom
Supreme Court Blocks Rastafarian's Religious Freedom Lawsuit Against Prison Officials, Departing from Recent Trends
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The Supreme Court ruled 6-3 on June 23, 2026, that a Rastafarian man cannot sue Louisiana prison officials who forcibly shaved his nearly knee-length dreadlocks — hair he had grown for 20 years as part of his faith. Bloomberg Law reported that the decision blocks inmates from seeking money damages against individual state officials under the federal religious freedom law known as RLUIPA.
The ruling is a sharp departure from recent Supreme Court terms, which had repeatedly expanded religious freedoms, according to The Washington Post. The victim, Damon Landor, had just three weeks left in his sentence when guards handcuffed him to a chair and shaved his head to the scalp.
Guards Shaved His Head With Three Weeks Left
Landor was serving a five-month sentence for a minor drug charge. Two earlier Louisiana prisons had respected his Rastafarian faith and left his dreadlocks alone. Then, in December 2020, he was transferred to the Raymond Laborde Correctional Center in Cottonport with just three weeks remaining.
When Landor arrived, he handed an intake guard a copy of a 2017 federal court ruling that said cutting Rastafarian dreadlocks violated the law. The guard threw it in the trash. Guards then handcuffed Landor to a chair and shaved his head completely, according to CP24. Even 15 of 17 judges on the 5th Circuit Court of Appeals later called the act "stark and egregious."
Court Rules Federal Law Does Not Allow Personal Lawsuits
Landor sued prison officials personally for money damages under RLUIPA — the Religious Land Use and Institutionalized Persons Act, a 2000 law that protects prisoners' religious rights. Justice Neil Gorsuch wrote the majority opinion. He argued that RLUIPA was passed under the "Spending Clause," meaning it works like a contract between Congress and states. That contract, he said, never clearly told individual officials they could be personally sued.
Gorsuch contrasted RLUIPA with its "sister" law, RFRA, which applies to federal officials. In 2020, the Court ruled that RFRA does allow money damages against federal officers. Landor's lawyers argued the two laws use nearly identical language. The majority disagreed, citing the key difference in how each law was passed by Congress.
Dissenters Warn of a 'Right Without a Remedy'
Justice Ketanji Brown Jackson wrote the dissent, joined by Justices Sotomayor and Kagan. She argued the ruling creates a "right without a remedy." Because Landor was released from prison, he can no longer ask a court to order officials to stop — that window closed when he left. Now he cannot collect damages either. His case is worth exactly $0, according to CTV News.
Landor's attorney, Zachary Tripp, warned before the ruling that "without damages, officers could do the same thing tomorrow and their new victims would obtain no relief." Religious liberty groups like Becket said RLUIPA's protections are now "hollow" if officials can ignore the law once an inmate walks free.
Ruling Leaves Religious Minorities in Prison Exposed
Legal experts say the decision creates a dangerous loophole. If prison officials violate an inmate's religious rights and then transfer or release that person quickly, no lawsuit can follow. Critics say this gives officials an incentive to commit violations and move prisoners fast to avoid courts, according to The Washington Post.
Minority faiths — including Rastafarians, Sikhs, and Muslims — are most often targeted by prison grooming and diet policies. Without the threat of personal liability, advocates say there is little to stop officials from acting again. Louisiana's Solicitor General had argued that allowing such suits would "bankrupt individual correctional officers" — a concern the 6-3 majority found persuasive.
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