In a recent decision, the US Supreme Court ruled that Damon Landor, a Rastafarian inmate in Louisiana, cannot proceed with a lawsuit against the Louisiana Department of Corrections (LDOC) officers who forcibly shaved his dreadlocks. This decision, delivered by Justice Neil Gorsuch in a 6-3 opinion, focused on the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA) and its applicability to state employees in individual capacities. The core of the Court’s reasoning was that the sanctions under RLUIPA apply only to those who “knowingly and voluntarily agreed” to them. Therefore, while the LDOC can be sued under RLUIPA, the individual employees were not found liable as they did not consent to such suits.
The dissenting opinion, led by Justice Ketanji Brown Jackson, criticized the majority’s reliance on a contractual analogy, arguing that the decision conflates legislative authority with consensual agreements. Justice Jackson emphasized that Congress has historically used the Spending Clause, strengthened by the Necessary and Proper Clause, to reach indirect recipients of federal funds, opposing the majority’s new rule of consent.
RLUIPA, introduced in 2000 during the Clinton administration, prohibits state and local governments from imposing substantial burdens on religious exercise. It derives its authority from the Spending Clause of the Constitution, empowering Congress to allocate funds to states under federal compliance conditions. The statute allows plaintiffs to seek “appropriate relief against a government,” broadly defining “government” to include various governmental and state actors, a point underscored by several religious organizations supporting Landor’s case.
Landor himself has deeply held religious beliefs as a Rastafarian following the biblical Nazarite Vow to let his hair grow as a demonstration of devotion and holiness. Prior to his transfer to Raymond Laborde Correctional Center, he had complied with this vow for decades. Despite carrying a legal precedent from the Fifth Circuit affirming his religious rights, prison officials disregarded it, disposing of the document and forcibly cutting his hair.
This ruling contrasts with a recent trend of the Court favoring religious-freedom claims in various cases. For instance, in 2020, the Court allowed Muslim men to sue the FBI over unjust “No Fly List” placements, and in June 2025, it upheld parents’ rights to opt out of certain school curricula for religious reasons. Despite this setback, Landor remains undeterred, expressing his intent to continue seeking justice and accountability. More details on the case can be found here.