By Andrew Chung
WASHINGTON, June 23 (Reuters) – The U.S. Supreme Court refused on Tuesday to let a Rastafarian man sue state prison officials in Louisiana after guards held him down and shaved him bald in violation of his religious beliefs in a case brought under a federal law protecting incarcerated people from religious discrimination.
The court in a 6-3 ruling powered by its conservative justices upheld a lower court’s decision to dismiss Damon Landor’s lawsuit because it found the statute at issue did not permit him to sue the individual prison officials and guards for monetary damages. Landor’s religion requires him to let his hair grow.
The court’s three liberal justices dissented from the ruling, which was authored by conservative Justice Neil Gorsuch.
The law, called the Religious Land Use and Institutionalized Persons Act of 2000, or RLUIPA, prohibits religious discrimination by state and local governments in land-use regulations and also protects the religious rights of people confined to institutions such as prisons and jails.
The court ruled that because the law at issue implicates the power of Congress under the Constitution’s so-called Spending Clause, the measure may impose conditions only on the state or government entity that is the actual recipient of federal funds, not individual employees who do not themselves receive the funds – unless they consent.
Since the prison officials never agreed that they would be subject to lawsuits under RLUIPA, “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,” Gorsuch wrote.
Liberal Justice Ketanji Brown Jackson, writing in dissent, noted that RLUIPA is a law, not a contract.
“Today’s decision magically transforms a federal statute into an invitation to be accepted or declined, deemed binding only if each particular defendant has explicitly agreed to be penalized,” wrote Jackson, joined by Justices Sonia Sotomayor and Elena Kagan.
President Donald Trump’s administration backed Landor, urging the Supreme Court to revive the case.
The Supreme Court, which has a 6-3 conservative majority, had expanded the rights of religious people and institutions in a series of rulings in recent years. It heard arguments in the case in November.
Landor grew his hair over a span of 20 years into long locks that reached his knees. In 2020, near the end of a five-month prison sentence for drug possession, Landor was transferred to the Raymond Laborde Correctional Center in Cottonport, Louisiana.
There, Landor reminded officials that the New Orleans-based 5th U.S. Circuit Court of Appeals had ruled in a 2017 case that Louisiana’s policy of cutting the hair of Rastafarians violated the 2000 law.
Landor even handed over a copy of that ruling, but a guard threw it in the trash, according to court documents.
Landor was then handcuffed to a chair, held down and shaved.
Landor, who lives in Slidell, Louisiana, sued, but a federal judge threw out his case. In 2023, the 5th Circuit upheld that decision, concluding that the law at issue does not allow individual officials to be personally held liable for money damages.
In her dissent, Jackson said prisoners who experience religious freedom violations will now often be left without a remedy.
“And encroachments on prisoners’ statutory rights are likely to happen with fair frequency, as state-empowered prison officials will have little incentive to abide by federal law, even if it is handed to them on a piece of paper,” Jackson wrote.
Landor’s lawyers have called the statute similar to a 1993 law called the Religious Freedom Restoration Act that prohibits religious infringement by the federal government.
In 2020, the Supreme Court allowed for monetary damages claims under the Religious Freedom Restoration Act in a case involving a bid by three Muslim U.S. citizens to sue FBI agents who they accused of placing the men on the government’s “no-fly list” for refusing to become informants.
(Reporting by Andrew Chung; Editing by Will Dunham)
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