The Supreme Court agreed Monday to take up the case of a Rastafarian man seeking to sue prison officials in Louisiana who cut off his dreadlocks while he was incarcerated.
The case is the latest that involves religious rights to catch the high court’s attention, and it could have significant implications by allowing prisoners to sue government officials for damages when their religious rights are burdened under a federal law enacted 25 years ago.
Damon Landor, a devout Rastafarian who began serving a five-month prison sentence in 2020 for drug possession, had taken a religious vow years earlier to not cut his locks.
But his situation took a turn for the worse after arriving at a new prison weeks before his release. He handed officials a copy of an appeals court ruling from 2017 that allowed prisoners to have dreadlocks. The guards tossed it in the trash. They then handcuffed him to a chair and forcibly shaved his head.
Following Landor’s release, he sued Louisiana prison officials and guards for damages under a decades-old law that protects the religious interests of inmates. But lower courts dismissed his case, ruling that the law doesn’t allow individuals to pursue damages against prison officials for alleged violations of it even though, in one court’s view, he had been the victim of a “grave legal wrong.”
The conservative New Orleans-based 5th US Circuit Court of Appeals said in a unanimous decision last year that it “emphatically” condemned “the treatment that Landor endured,” but an earlier appeals court precedent settled the case against him. The full 5th Circuit divided on whether to hear the case.
President Bill Clinton signed the bipartisan law in 2000 that protects the religion interests of state prisoners but it’s not clear whether that law allows people who were harmed to sue for money damages. The Supreme Court ruled in 2020 that a similar law with nearly identical language allows people whose religious rights have been burdened to seek damages against government officials acting in their individual capacity.
“Without a damages remedy,” lawyers for Landor told the justices in court papers, inmates “will often be left without meaningful protection for their religious exercise.”
In other words, once Landor’s head was shaved, the only way for him to have some legal remedy is through monetary damages.
“The no-damages rule ensured that respondent officials would not be held accountable for violating the religious rights of a prisoner set for release in just three weeks and prevented him from obtaining any relief for the abuse he suffered,” his lawyers said.
Attorneys for the Louisiana state officials urged the court to not take up the case, arguing among other things that Landor could bring his claims under state law. They also told the justices that permitting the lawsuit to move forward could hamper the state’s ability to hire staff in its prisons.
Siding with Landor, they told the court, “would almost certainly deepen the problem by driving down staffing levels and dissuading job applicants.”
“That, in turn, inevitably would lead to worse prison conditions and perhaps lessened protections for religious liberty, as understaffed prisons attempt to survive the growing prison populations,” they added. “No one wins in that situation.”
The Trump administration, meanwhile, had asked the justices to take up the matter. Solicitor General D. John Sauer told the court in May that the federal government has an interest “in ensuring that prisons or other institutions receiving federal funds do not substantially burden religious exercise, and damages liability is closely connected to that interest.”
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