Supreme Court denies damages for Rastafarian dreadlock shaving

WASHINGTON (CN) — In a rare ruling against religious rights, the Supreme Court said Tuesday that a Rastafarian man could not seek damages from Louisiana prison officials who shaved his dreadlocks.

Dividing along ideological lines, the high court rejected Damon Landor's lawsuit under the Religious Land Use and Institutionalized Persons Act because it targeted officials at Louisiana's Raymond Laborde Correctional Center, not the center itself.

According to the conservative majority, the prison consented to uphold Landor's rights under RLUIPA by accepting federal funds. But Justice Neil Gorsuch, a Donald Trump appointee, said that individual officers made no such commitment.

"Certainly, an agent usually must obey his principal's directions and sometimes may bind his principal," Gorsuch wrote for the six-justice majority. "But when a principal (here, LDOC) enters a contract with a third party (here, the federal government), as a matter of blackletter contract law the principal's agents do not become 'liable' to the third party for their principal's 'nonperformance.'"

Justice Ketanji Brown Jackson, a Joe Biden appointee, said the majority's holding left inmates like Landor who suffer from violations of their religious freedoms remediless and gave prison officials little incentive to abide by federal law.

"Today's decision magically transforms a federal statute into an invitation to be accepted or declined, deemed binding only if each particular defendant has explicitly agreed to be penalized," Jackson wrote for the three liberal justices in dissent.

Under RLUIPA, Rastafarians like Landor who maintain dreadlocks as a demonstration of their religious beliefs are exempt from prison hair standards. For the first four months of his five-month prison sentence in fall 2020, administrators at two facilities allowed Landor to keep his dreadlocks.

When he was transferred to Raymond Laborde, Landor gave the intake guard documentation of his religious accommodations, including a Fifth Circuit opinion holding that Louisiana's policy of cutting the hair of Rastafarians violated federal law.

The guard discarded the documents, according to Landor, and the prison warden refused to give him time to obtain additional documentation from his sentencing judge. Prison officials handcuffed Landor to a chair, held him down and shaved his head. He was kept in lockdown for the last three weeks of his sentence.

Two lower courts dismissed Landor's lawsuit against Louisiana corrections officials, concluding that his claims were moot because he was no longer in prison. Landor asked the Supreme Court to provide a path for accountability that allows him to pursue damages for the violation of his religious rights.

In 2020, the high court unanimously held that individual federal officials could face monetary damages for violating the Religious Freedom Restoration Act, or RFRA, in Tanzin v. Tanvir. But the Supreme Court's long-running tug-of-war with Congress bound RLUIPA protections to state programs that receive federal funds.

So-called spending clause statutes like RLUIPA create a contract between the federal government and the recipient of funds. State prisons entered this kind of agreement by accepting federal Medicaid funds on the condition that they abide by RLUIPA and similar laws.

Landor said prison officials got a cut of those funds through their paychecks. Though indirect, he argued the guards implicitly consented to liability under the law.

During oral arguments in Landor's case in November 2025, however, the conservative justices were concerned that Louisiana prison officials had adequate notice of the consequences they could face by violating federal law.

That concern was echoed in Thursday's opinion. Gorsuch said such implicit consent liability would give Congress unbridled police power through spending clause legislation.

"On Mr. Landor's theory, Congress could require coaches at universities that receive federal funds to permit transgender athletes to play women's sports — or face personal liability in suits for damages," Gorsuch wrote. "Likewise, Congress could bar doctors at medical practices that accept federal funds from administering certain vaccines to children — again on pain of damages."

Jackson claimed the majority's analysis was "spellbindingly straightforward."

"But pulling this rabbit out of the hat requires misconstruing the spending clause and the necessary and proper clause, and ignoring decades of precedent affirming Congress' authority to use the power of the purse to govern," Jackson wrote.

She said the spending clause contains no direct-consent requirement. While Congress' authority isn't unlimited, Jackson said, the Constitution gave legislators authority to legislate.

Jackson said this authority is also supported by the necessary and proper clause, which empowers Congress to enact laws under its enumerated powers — including spending power — that are not within its authority to enact in isolation.

"In the end, the court reduces some of Congress' greatest legislative achievements — federal laws that secure civil rights, environmental stability, healthcare and more — to nothing more than the wheelings-and-dealings of an especially wealthy private party," Jackson wrote. "Because I would not so trivialize a federal statute or the constitutional powers pursuant to which it was passed, I respectfully dissent."

Religious and civil rights groups supporting Landor worry the ruling endangers the rights of incarcerated people who are particularly vulnerable to abuse.

"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," Rachel Laser, CEO and president of Americans United for Separation of Church and State, said. "We can only hope this faulty decision doesn't embolden more prison officials to ignore the religious-freedom rights of incarcerated people to observe their faith as long as they don't harm others."