The Supreme Court ruled 6-3 on Tuesday, June 23, 2026, that Damon Landor, a Louisiana inmate who said guards forcibly shaved his dreadlocks in violation of his Rastafari faith, cannot seek money damages from the officers under the Religious Land Use and Institutionalized Persons Act.
Damon Landor, who follows the Rastafari faith and said he had not cut his hair for about 20 years under a Nazirite vow, alleged that Louisiana prison guards forcibly shaved his head after he was transferred to a different facility in 2020.
Landor told officials he had a court decision requiring the Louisiana Department of Corrections to accommodate Rastafarian hair practices, but he said officers ignored it. He later sued under the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), seeking damages from state officers in their personal capacities.
In a 6-3 decision, the Supreme Court held that RLUIPA does not authorize money-damages suits against individual state employees in their personal capacities. Writing for the majority, Justice Neil Gorsuch said the statute was enacted under Congress’s Spending Clause authority—treating federal-funding conditions as a form of agreement—and that individual employees who did not voluntarily and knowingly accept personal liability cannot be held to pay damages.
Justice Ketanji Brown Jackson dissented, joined by the court’s other two liberal justices. She argued the decision narrows remedies for violations of religious rights in prison and warned it could have implications for other federal statutes that rely on Spending Clause authority.
The ruling leaves inmates able to pursue other forms of relief, including injunctions against prison systems and officials in their official capacities, though such remedies can be harder to obtain when prisoners are moved between facilities.
The case is Landor v. Louisiana Department of Corrections and Public Safety.
