Supreme Court Bars Money Damages Against Individual Prison Officials Under Religious Land Use Law

The U.S. Supreme Court on Tuesday barred former Louisiana inmate Damon Landor from suing prison officials for money damages after they cut his dreadlocks during his 2020 incarceration. The 6-3 decision held that the Religious Land Use and Institutionalized Persons Act does not permit lawsuits seeking financial compensation from individual officers.

Justice Neil Gorsuch wrote the majority opinion, stating that nothing in the law authorizes suits against individual officers. The court declined to extend the rationale from its 2020 decision allowing Muslim men to sue over the FBI no-fly list under a related statute. The incident occurred at the Raymond Laborde Correctional Center in Cottonport, about 80 miles northwest of Baton Rouge.

Landor served the final three weeks of his five-month term there. Officials at his first two prison stops had respected his Rastafari beliefs. A guard discarded a copy of an appeals court ruling Landor carried that protected religious prisoners' dreadlocks.

The warden then ordered the cutting. Two guards restrained Landor while a third shaved his head to the scalp. Justice Ketanji Brown Jackson dissented, joined by the court's two other liberal justices.

She wrote that state prison officials will have little incentive to follow federal law. The Justice Department had sided with Landor in the case. Louisiana amended its prison grooming policy after the incident to prevent similar occurrences.

Landor had sued after his release, but lower courts dismissed the case.