The U.S. Supreme Court recently showcased reservations regarding a religious liberty claim brought forth by Damon Landor. Landor, a prisoner and devout Rastafarian, alleged rights violations under the Religious Land Use and Institutionalized Persons Act (RLUIPA) after prison officials forcibly shaved his dreadlocks, contravening a previous federal ruling that his religious expression should be protected.
During the oral arguments, the justices deliberated whether RLUIPA allows for monetary damages against state officials sued in their personal capacities, a core aspect of Landor’s claim. Previous 5th Circuit rulings, as cited in cases such as Cutter v. Wilkinson, have found no precedent for such claims under RLUIPA. Justice Brett Kavanaugh questioned if Landor had the requisite “clear statement” to substantiate claims of money damages, emphasizing the opacity of the term “appropriate relief.” Similarly, Justices Gorsuch and Alito reinforced skepticism due to historical judicial consensus opposing individual capacity suits under the act.
For the petitioner, attorney Zachary Tripp argued that RLUIPA should mirror the rights covered under the Religious Freedom Restoration Act, a law that does permit personal capacity suits. A recent Supreme Court ruling in Tanzin v. Tanvir was cited to bolster this argument, characterizing RLUIPA and RFRA as akin to “twins separated at birth.”
In contending against Tripp’s position, Benjamin Aguinaga, representing Louisiana, suggested that legislative, not judicial, bodies should define the availability of monetary damages. He noted Congress’s legislative action, rather than judicial interpretation, would be the proper avenue for such reform.
Despite the discernible skepticism, the case demonstrated differing opinions among the justices. Justice Ketanji Brown Jackson and Justice Elena Kagan expressed alignment with the petitioner’s standpoint, emphasizing existing precedents for suits against state officials. Justice Sonia Sotomayor proposed a nuanced resolution, suggesting a ruling to clarify potential future liability for similar cases.
In the interim, both the decision of the Supreme Court and its broader implications for religious rights in correctional institutions remain to be seen. The case, Landor v. Louisiana Department of Corrections, is poised for a decision by mid-2025.
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