The Supreme Court has ruled that a Louisiana man who said prison guards forcibly cut his locs despite his Rastafari beliefs cannot sue the officers involved, delivering a decision that could have wide-ranging implications for how incarcerated people enforce federal religious protections.
According to CNN, in a 6-3 ruling issued on Tuesday, June 23, the court sided against Damon Landor, a devout Rastafari follower who argued that officials at Louisiana's Raymond Laborde Correctional Center violated his religious rights when they restrained him and cut the knee-length locs he had maintained for nearly two decades.
Justice Neil Gorsuch, writing for the majority, said Congress had not clearly authorized lawsuits against individual state employees under the Religious Land Use and Institutionalized Persons Act, commonly known as RLUIPA. "None of that is consistent with our precedents," Gorsuch wrote, rejecting arguments that federal prison funding automatically exposed individual officers to liability.
Landor had only weeks remaining on a five-month drug possession sentence when the incident occurred in 2020. Before being transferred to Raymond Laborde, he had spent time in two other facilities without any hair-related issues.
A follower of the Nazarite vow, Landor arrived carrying a copy of a 2017 appeals court ruling that recognized prisoners' rights to wear locs for religious reasons. According to court filings, guards discarded the document before handcuffing him to a chair and cutting his hair.
The ruling sparked a sharp dissent from Justice Ketanji Brown Jackson, who warned that the decision leaves inmates with limited options when their religious freedoms are violated. "Prisoners like Landor who suffer violations of their religious freedom in state prisons — no matter how blatant — will often be left remediless," Jackson wrote.
She added that prison officials would have "little incentive to abide by federal law, even if it is handed to them on a piece of paper."
Landor's case centered on RLUIPA, legislation passed by Congress to protect religious exercise inside institutions such as prisons. In recent years, the Supreme Court has frequently ruled in favor of religious claimants, backing a high school football coach's right to pray on the field and supporting religious parents seeking exemptions from LGBTQ-themed classroom materials.
Rachel Laser, president and CEO of Americans United for Separation of Church and State, criticized the outcome, saying, "Once again, we see a court that will bend over backward for the religious freedom of Christians but allows the government to trample the religious freedom of non-Christians."
While the Federal Bureau of Prisons generally permits long hair and locs if they are kept clean, state and county facilities often impose stricter standards because of concerns about contraband and safety.
Some institutions require inmates to tie their hair back, prohibit beads and metal accessories, and conduct additional searches. Others have been forced to revise their rules after challenges brought under RLUIPA and the First Amendment.
