The U.S. Supreme Court ruled 6-3 on Monday that a devout Rastafarian man whose dreadlocks were forcibly cut by prison guards cannot seek monetary damages from those individual officials, even though the Court acknowledged his religious rights were violated. The case raises significant questions about the practical enforceability of religious liberty protections for incarcerated Americans.

What Happened

Damon Landor had observed his Rastafarian faith for nearly two decades, wearing dreadlocks as a religious practice. While serving a five-month prison sentence — with only weeks remaining — he was transferred to the Raymond Laborde Correctional Center in Louisiana, where guards cut off his dreadlocks. Landor subsequently filed suit against the individual prison officials, seeking monetary damages under the Religious Freedom Restoration Act (RFRA) and the Religious Land Use and Institutionalized Persons Act (RLUIPA).

The Supreme Court upheld the Fifth Circuit’s earlier ruling against Landor, concluding that while the prison system itself may be subject to suit, individual state employees cannot be held personally liable for monetary damages under RLUIPA’s framework. The majority opinion, authored by Justice Neil Gorsuch and joined by five colleagues, turned on the constitutional basis for the law itself.

The Legal Reasoning

Central to the majority’s analysis was the legal foundation on which Congress enacted RLUIPA. Because the law was passed under the Constitution’s Spending Clause — which conditions federal funding to states on their agreement to certain requirements — the Court held that its obligations run between the federal government and the states as institutional recipients of those funds, not between the federal government and individual state employees.

Justice Gorsuch wrote that “under the Spending Clause, Congress lacks regulatory authority to impose them directly and must depend instead on consent.” Under that framework, individual guards cannot be treated as parties bound by conditions that their employer-state accepted.

During oral arguments, Chief Chief Justice John Roberts articulated the same principle, describing RLUIPA’s spending clause provision as a contract between the federal and state governments rather than a binding obligation on individual state workers.

The distinction matters practically: Landor is not foreclosed from suing the prison system itself, but recovering from an institution is a different and often more difficult undertaking than seeking damages from the individuals directly responsible for the harm.

A Dissent Centered on Remedies

Justice Ketanji Brown Jackson, joined by Justices Elena Kagan and Sonia Sotomayor, dissented from the ruling. Landor’s attorney, Zachary Tripp, captured the dissent’s central concern: without the ability to pursue damages from the individuals who carried out the violation, an inmate’s religious rights being violated become, in his words, “meaningless.”

The dissenting justices argued that allowing acknowledged violations of religious freedom to go without meaningful remedy for the injured party weakens the very protections Congress intended when it passed RLUIPA. The Trump administration had sided with Landor, supporting his right to sue the guards directly — a position the majority ultimately rejected.

A Catholic Perspective on Religious Liberty Behind Bars

For Catholics attentive to the Church’s teaching on human dignity and religious freedom, the case presents a genuine tension. The Catechism of the Catholic Church affirms that “the right to religious freedom” is grounded in the dignity of the human person and belongs to every individual — a dignity that does not disappear at the prison gate. Catholic social teaching has long held that even those who forfeit certain civil freedoms through criminal conduct retain their fundamental human dignity and their right to practice their faith.

The Church’s tradition of prison ministry — and its consistent advocacy for the humane treatment of prisoners — rests on precisely this conviction. The forced removal of a religious symbol worn for twenty years, by a man with weeks left on a short sentence, would strike most Catholic moral theologians as a gratuitous injury to his dignity.

At the same time, the Court’s decision is procedural rather than substantive: it does not say religious rights in prison are unprotected, but rather that one specific legal avenue for enforcing them is closed. Landor retains the right to pursue the prison system through institutional channels, even if he cannot reach the guards individually.

Cases like this one, and ongoing litigation over religious freedom protections for faith-based institutions, reflect a broader moment of legal recalibration around RFRA and RLUIPA — laws passed with bipartisan support to shield sincere religious practice from unnecessary government interference. How courts interpret their scope and remedy structures will shape religious liberty in America for years to come.