The U.S. Supreme Court (SCOTUS) ruled against a former Louisiana inmate and devout Rastafarian who sought to sue state prison officials for cutting his dreadlocks, claiming it to be a violation of his religious beliefs.
In a 6-3 ruling, the high court rejected Damon Landor’s attempts to sue the Louisiana Department of Corrections and Public Safety and prison officials for violations of the Religious Land Use and Institutionalized Persons Act (RLUIPA).
Divided along ideological lines, with the three liberal justices in dissent, the conservative majority ruled that RLUIPA does not permit lawsuits for money damages against individuals even if religious rights are violated.
The high court’s ruling upholds the U.S. Court of Appeals for the 5th Circuit’s rejection of his request to reignite his case against the officers.
Majority Opinion
In the majority opinion, Justice Neil Gorsuch affirmed that Landor "does not have a federal RLUIPA cause of action against the officers. Under the Spending Clause, Congress lacks regulatory authority to impose liability on them directly and must depend instead on consent. And because they never agreed to answer suits like this one, Mr. Landor's case cannot proceed against them any more than a breach of contract action might proceed against a defendant who never formed a contract."
Dissenting Opinion
In a dissenting opinion authored alongside Justices Sonia Sotomayor and Elena Kagan, Justice Ketanji Brown Jackson criticized the majority’s "full-throated endorsement of a contract analogy.”
Justice Jackson asserted that “prisoners like Landor who suffer violations of their religious freedom in state prisons — no matter how blatant — will often be left remediless.”
Officials Recognize Mistreatment
The state of Louisiana did not dismiss Landor’s unfair treatment, confirming that the prison system has since overhauled its grooming policy to ensure other Rastafarian prisoners do not endure similar situations.
The state, however, argued that RLUIPA applies to federal, not state, officials.
The 5th U.S. Circuit Court of Appeals echoed the same words, lamenting Landor’s treatment but ruling that the law doesn’t allow him to hold prison officials liable for damages.
