No Damages for Dreadlocks Shaving
Supreme Court Rules Rastafarian Prisoner Cannot Sue Guards for Religious Rights Damages
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Key Points
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In a 6-3 ruling, the Supreme Court held that Landor cannot sue state prison guards for damages under RLUIPA because there was no federal agreement binding the individual defendants, highlighting a Spending Clause constraint that private liability requires a federal agreement or contract.
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Dissenting justices argued the decision narrows religious protections and criticized the majority's reasoning, with Justice Jackson describing the ruling as 'magically transforms a federal statute into an invitation to be accepted or declined,' asserting that laws are not contracts.
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The Landor case drew political and institutional support for him, including backing from the Trump administration and briefs filed by Republican lawmakers such as Senators Ted Cruz and Ted Budd, plus the Becket Fund for Religious Liberty.
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The incident at the Raymond Laborde Correctional Center occurred in 2020 when Landor, near the end of a five-month drug-sentence, was handcuffed to a chair and shaved after presenting a court ruling that Rastafari grooming rules should be accommodated; guards discarded the ruling during the confrontation.
The Supreme Court ruled 6-3 on June 23, 2026 that Damon Landor, a Rastafarian prisoner in Louisiana, cannot sue the prison guards who shaved off his dreadlocks in 2020. The majority held that the federal law protecting religious rights in prisons — known as RLUIPA — does not let prisoners sue individual state officials for money damages, according to CBS News.
Landor had maintained his hair for nearly 20 years as part of his Rastafarian faith. Guards at Raymond Laborde Correctional Center handcuffed him to a chair and shaved his head with just three weeks left on a five-month drug sentence, PBS reported. He had even handed them a court ruling saying his dreadlocks were protected — officials threw it in the trash.
Why RLUIPA's Spending Clause Blocked Landor's Lawsuit
RLUIPA — the Religious Land Use and Institutionalized Persons Act — applies to state prisons that receive federal money. Justice Neil Gorsuch wrote the majority opinion. He said RLUIPA is a "Spending Clause" law, meaning it works like a contract between the state and the federal government. "Under the Spending Clause, Congress lacks regulatory authority to impose liability on officials directly and must depend instead on consent," Gorsuch wrote, according to CBS News.
Because individual prison guards never personally agreed to federal funding conditions, the majority said they cannot be held personally liable for money damages. Louisiana as a state accepted federal funds — and can be sued for injunctive relief, meaning a court order to stop bad behavior. But that remedy was useless for Landor. He was already released before any lawsuit could force the prison to change course, Newsweek reported.
Guards Threw Out a Court Order, Then Cut His Hair
On December 28, 2020, Landor arrived at the Raymond Laborde Correctional Center. He had grown his hair for 20 years under what Rastafarians call a Nazarite Vow. He handed guards a federal court ruling that explicitly protected Rastafarian dreadlocks, according to the Becket Fund for Religious Liberty. Officials discarded the document, handcuffed Landor to a chair, and shaved his head down to the scalp.
Landor later sued Warden Marcus Myers and other officials for money damages. The Fifth Circuit Court of Appeals threw out the case in September 2023. The Supreme Court agreed to hear it in June 2025 and held oral arguments in November 2025, according to Ballotpedia.
Rare Coalition — Trump DOJ, GOP Senators, Liberal Justices — All Lost
Landor drew an unusual set of supporters. The Trump administration's Justice Department filed a brief on his side, arguing RLUIPA's language allowing "appropriate relief" includes money damages, PBS reported. Republican Senators Ted Cruz and Ted Budd filed supporting briefs. So did 44 religious organizations, including the Sikh Coalition and the Jewish Coalition for Religious Liberty, according to the Becket Fund for Religious Liberty.
None of it worked. The six conservative justices sided with the state on federalism grounds, splitting from their usual pro-religion allies. Justices Ketanji Brown Jackson, Sonia Sotomayor, and Elena Kagan dissented. Jackson wrote that the ruling "magically transforms a federal statute into an invitation to be accepted or declined," adding that laws are not contracts, according to CBS News.
Prisoners With Short Sentences Now Have No Real Remedy
The ruling creates a practical gap for prisoners like Landor. An injunction — a court order saying "stop doing that" — is the only other remedy under RLUIPA. But short-term inmates are often released before a court can issue one. The Becket Fund called this a "rights without remedies" problem. "Damages are the only viable remedy" for prisoners who are released before winning an injunction, the group argued, according to the New York Post.
Critics now want Congress to rewrite RLUIPA and explicitly allow personal damages suits against individual state officials. Louisiana has already updated its prison grooming policy since the 2020 incident. But the ruling means guards in other states face no personal financial risk for ignoring similar policies, according to Yahoo News.
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