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

The U.S. Supreme Court ruled Tuesday that the Religious Land Use and Institutionalized Persons Act does not authorize money-damages suits against individual state prison officials. The 6-3 decision ended a lawsuit by Damon Landor, a Rastafarian who served five months in the Louisiana prison system in 2020.

Landor had sued after guards at the Raymond Laborde Correctional Center in Cottonport cut his dreadlocks against his religious objections. Justice Neil Gorsuch wrote the majority opinion. The court held that the statute provides no exception allowing financial liability for individual officers.

Justice Ketanji Brown Jackson dissented, joined by the court's two other liberal justices. She wrote that prison officials would have little incentive to follow federal law without the threat of damages. Landor carried a copy of a prior appeals court ruling stating that cutting religious inmates' dreadlocks violated federal law.

A guard discarded the document, according to court records. The warden then ordered the haircut, which two guards carried out while a third shaved Landor's head to the scalp. Lower courts, including the 5th U.S.

Circuit Court of Appeals, dismissed the suit on the same statutory grounds. The Supreme Court declined to extend its 2020 reasoning from a Religious Freedom Restoration Act case involving the FBI no-fly list. The Justice Department sided with Landor.

Louisiana stated that it has since amended its prison grooming policy.