The Supreme Court ruled 6-3 on Monday that a Louisiana prisoner cannot collect monetary damages from the individual guards who forcibly shaved his dreadlocks — hair he had grown for more than two decades as part of a religious vow — because federal law does not make those officers personally liable for such suits.

The case, Landor v. Louisiana Department of Corrections and Public Safety et al., centered on Damon Landor, a Rastafarian inmate who had maintained his dreadlocks for at least 20 years in observance of the biblical Nazirite vow. Near the end of a five-month prison stay in 2020, he was transferred to the Raymond Laborde Correctional Center in Cottonport, Louisiana, where guards physically restrained him and shaved his head.

The Legal Question

Landor brought suit under the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), the federal statute designed to protect the religious exercise of prisoners and other institutionalized persons. He sought monetary damages from both the Louisiana Department of Corrections and the individual guards responsible. After lower court proceedings, the case against the department was dropped, and Landor pursued his claims against the officers in their personal capacities.

The central dispute was whether RLUIPA allows prisoners to sue individual prison officials personally for damages. Ten federal courts of appeals had previously concluded it does not, and the Supreme Court’s conservative majority agreed.

Associate Justice Neil Gorsuch, writing for the majority, grounded the ruling in the Constitution’s Spending Clause. RLUIPA operates as a condition attached to federal funding that states and their institutions accept. Because individual officers never personally agreed to those conditions, Gorsuch reasoned they could not be personally sued under the statute. “Individuals may not be held liable in their personal capacities under a spending clause statute unless those individuals have voluntarily and knowingly consented to answer lawsuits under the statute,” he wrote.

The Dissent

Associate Justice Ketanji Brown Jackson, joined by Justices Elena Kagan and Sonia Sotomayor, disagreed sharply. The three liberal justices argued in dissent that blocking personal liability left prisoners whose religious rights are violated without a meaningful legal remedy — a result they found difficult to square with the statute’s protective purpose.

The dissent’s concern drew broader agreement from religious liberty advocates across ideological lines. Evan Lenow, president of the Ethics and Religious Liberty Commission of the Southern Baptist Convention, lamented the practical consequences of the ruling. “Whether it is burning a Christian’s family Bible, destroying a Jewish person’s yarmulke, or shaving a Rastafarian’s hair, our justice system should ensure there are appropriate methods of relief to right unjust wrongs,” he said.

What the Ruling Does and Does Not Decide

The majority’s holding is narrow in a technical sense: it addresses only the availability of monetary damages against officers sued personally under RLUIPA. The decision does not foreclose all avenues of relief for prisoners facing religious coercion. Injunctive relief — court orders requiring officials to stop or change a practice — may still be available under the statute, and prisoners may have other legal theories depending on the circumstances.

Louisiana Attorney General Liz Murrill noted that the state has since adopted policies intended to prevent similar religious liberty violations from occurring, suggesting that institutional reform, rather than individual officer liability, may be the path the state has chosen.

A Catholic Perspective

The case raises questions that Catholic social teaching takes seriously. The Catechism of the Catholic Church affirms that religious freedom is a natural right rooted in the dignity of the human person, and that it extends to individuals in every circumstance — including those who are incarcerated. The Church has consistently taught, from Dignitatis Humanae onward, that the state must protect rather than suppress the interior and exterior acts by which a person relates to God.

When prisoners — already among the most vulnerable members of society — are stripped of religious practice by the very officers entrusted with their care, the question of accountability is not merely procedural. The ruling in Landor may be legally sound under the Spending Clause framework, but it underscores a real gap: federal law, as currently written, leaves prisoners who suffer genuine religious harm without a direct financial remedy against the individuals who caused it.

Whether Congress acts to close that gap — by amending RLUIPA or creating a separate cause of action — remains to be seen. For now, the decision stands as a reminder that legal structure and moral accountability do not always align, and that the fight over religious liberty in institutional settings is far from resolved.