The United States Supreme Court has ruled that a devout Rastafarian inmate whose knee-length dreadlocks were forcibly cut by prison officials cannot sue individual state prison officers for monetary damages.
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The court, in a 6-3 decision delivered on Tuesday, ruled against Damon Landor, who had sought to sue officials of the Louisiana Department of Corrections for allegedly violating his religious rights.
Landor, who had not cut his hair for nearly 20 years in line with his Rastafarian faith, was serving the final weeks of a five-month sentence for drug possession in 2020 when the incident occurred.
According to court records, Landor had been transferred to Raymond Laborde Correctional Center in Cottonport, Louisiana, shortly before the end of his sentence when prison guards ordered him to cut off his dreadlocks, which had grown to his knees.
Landor reportedly showed the guards a copy of a 2017 court ruling stating that Rastafarian inmates should be allowed to keep their dreadlocks in accordance with their religious beliefs and federal law.
However, one of the guards allegedly threw the document away, after which Landor was handcuffed to a chair and his head was shaved bald.
Louisiana later acknowledged that the treatment of Landor was “antithetical to religious freedom” and amended its prison grooming policy.
However, the state argued that federal law did not allow Landor to seek monetary damages from state prison officials sued in their individual capacities.
The Supreme Court agreed with Louisiana, holding that Landor could not pursue damages against the individual officials under the Religious Land Use and Institutionalized Persons Act.
Justice Neil Gorsuch wrote the majority opinion, stating that Landor’s argument would require the court to accept that individuals could be personally regulated merely because federal funds indirectly reached them through state prison funding.
“Mr. Landor would have us hold, for the first time, that so long as a penny of federal spending makes its way to an individual, however indirectly, Congress can regulate his conduct directly based on the fiction that he has consented to regulation,” Gorsuch wrote.
“None of that is consistent with our precedents,” he added.
The three liberal justices dissented, with Justice Ketanji Brown Jackson writing the dissenting opinion.
Jackson warned that the ruling would leave many prisoners without an effective remedy when their religious rights are violated by state prison officials.
“Prisoners like Landor who suffer violations of their religious freedom in state prisons — no matter how blatant — will often be left remediless,” Jackson wrote.
She added that violations of prisoners’ statutory rights were likely to continue because prison officials would have little incentive to obey federal law, “even if it is handed to them on a piece of paper.”
The 5th U.S. Circuit Court of Appeals had earlier condemned Landor’s treatment as “egregious” but ruled that existing precedent did not allow him to sue individual prison officials for damages.
Rights advocates criticised the Supreme Court’s decision. Rachel Laser, president and CEO of Americans United for Separation of Church and State, described the ruling as hypocritical.
“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,” Laser said.
Rastafarians traditionally allow their hair to grow, often in dreadlocks, as part of their religious beliefs. The religion originated in Jamaica and was popularised globally by late reggae icon Bob Marley.
The ruling could have broader implications for prisoners seeking to enforce religious rights against state officials, particularly where monetary damages are sought for past violations.
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