US Supreme Court Rules Rastafarian Man Can't Sue Prison Officials

The Supreme Court's Ruling

The United States Supreme Court has determined that a Rastafarian man cannot sue prison officials who cut his dreadlocks for violating his religious beliefs.

On Tuesday, the court’s conservative majority ruled that Damon Landor, a formerly incarcerated man, cannot file a lawsuit against prison staff for violations of the Religious Land Use and Institutionalized Persons Act (RLUIPA), a law meant to uphold religious liberties for those behind bars.

The Case Details

Landor served a five-month prison term in Louisiana in 2020. He is Rastafarian, a religion that requires him to grow his hair as a sign of his faith. As he entered the prison system, he carried a copy of a 2017 appeals court ruling that found that cutting a religious prisoner’s dreadlocks violated federal law.

Prison officials initially respected Landor’s beliefs. But after he was transferred to the Raymond Laborde Correctional Center in Louisiana, a prison guard threw the document in the trash, and the facility’s warden then ordered his hair cut, according to court filings.

Two guards held Landor down as a third shaved his head.

The Legal Implications

Writing for the majority, Justice Neil Gorsuch did not argue that Landor’s religious rights had not been violated. Instead, he wrote that it was improper to sue the prison officials, as they had not consented to be liable under the RLUIPA law.

“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.

The ruling upheld a lower court’s decision which found that incarcerated people cannot seek financial damages from individual employees, even in cases where their rights were violated.

The Dissent and Future Implications

The court’s three liberal justices dissented, arguing that RLUIPA is a law rather than a contract. Writing for the dissent, Justice Ketanji Brown Jackson argued that the distinction was key. Prison officials, she said, would have little reason to abide by legal protections for prisoners, absent any consequences for their actions.

“It is not often that a real-life incident so clearly illustrates Congress’s reasons for adopting legislation, or the Constitution’s wisdom in enabling it,” Brown Jackson wrote.

Landor, however, released a statement through his lawyers indicating he would continue his pursuit of justice. “I am disappointed but not defeated,” Landor said in a statement from his lawyers. “What happened to me violated my faith and my dignity. I will continue pursuing accountability. What happened to me should not happen to anyone else.”