The U.S. Supreme Court ruled 6-3 on June 23, 2026, that a Louisiana prisoner who had his head forcibly shaved by prison officials cannot sue those employees personally for monetary damages, even though the shaving violated his religious convictions as a devout Rastafarian.
Damon Landor had kept his hair uncut for two decades as an expression of his Rastafarian faith. According to news reports, prison guards shaved his head against his will, an act Landor described as a direct attack on both his beliefs and his dignity. “What happened to me violated my faith and my dignity,” he said.
The Legal Question
The case turned on the interpretation of the Religious Land Use and Institutionalized Persons Act (RLUIPA), a federal law enacted in 2000 to protect the religious exercise of people in government institutions, including prisons. Landor argued that the law gave him the right to seek financial compensation from the individual state employees responsible for the shaving.
Justice Neil Gorsuch authored the majority opinion, holding that RLUIPA does not authorize inmates to pursue money damages against prison officials acting in their personal capacities. The ruling aligned with the existing position of all ten federal circuits that had previously addressed the question, each of which had reached the same conclusion.
The three liberal justices — Sonia Sotomayor, Elena Kagan, and Ketanji Brown Jackson — dissented. Justice Jackson warned that the ruling would leave many incarcerated people without any practical remedy when their religious freedom is violated. “Prisoners like Landor who suffer violations of their religious freedom in state prisons will often be left remediless,” she wrote.
What Remains Available to Prisoners
The ruling does not strip incarcerated people of all legal recourse. RLUIPA still permits suits against state institutions themselves and can compel prisons to change policies or practices that burden religious exercise. What the Court foreclosed is the ability to obtain money from individual employees — a distinction that critics argue leaves the most direct remedy off the table for people who have already suffered a concrete harm.
Louisiana Attorney General Liz Murrill noted that her state has its own statutes protecting religious liberty, suggesting that Landor and others in similar situations may have avenues under state law that the federal ruling does not address.
The Church’s Stake in Religious Liberty Behind Bars
The Catholic Church has long held that human dignity does not diminish at the prison gate. The Catechism teaches that every person retains an inherent dignity that no circumstance can erase, and the Church’s tradition of prison ministry reflects a consistent conviction that incarcerated people remain full members of the human family deserving of respect.
Religious practice in particular has been recognized by the Church as essential to the rehabilitation and spiritual welfare of those who are incarcerated. Pope Leo XIV, in continuity with his predecessors, has emphasized that integral human development includes the spiritual dimension of each person — a principle that applies with full force to those in state custody.
The question of whether federal law adequately enforces that dignity for prisoners is now, in practical terms, a matter left largely to Congress and to state legislatures. The Court’s ruling is a statutory interpretation, not a constitutional one, meaning lawmakers could amend RLUIPA to permit the kind of individual damages suit Landor sought.
What Comes Next
Landor said he remains determined despite the setback. Advocates for prisoner religious rights are expected to press Congress to revisit the damages provisions of RLUIPA in light of the ruling. Whether that effort will gain traction in the current legislative environment is uncertain.
For now, the decision reinforces a legal landscape in which the most meaningful protection for a prisoner’s religious exercise is prospective — forcing a change in policy — rather than compensatory, offering no personal redress for an injury already inflicted.