Washington — The Supreme Court said Monday that it will consider a religious rights case brought by a former Louisiana inmate who is seeking to sue Louisiana prison officials for money damages for shaving his dreadlocks in violation of his religious beliefs.
The high court will review a decision from the U.S. Court of Appeals for the 5th Circuit that said the former inmate, Damon Landor, could not seek monetary damages against the officials in their individual capacities under the Religious Land Use and Institutionalized Persons Act, or RLUIPA.
Landor is a devout Rastafarian who pledged to “let the locks of the hair of his head grow,” known as the Nazarite Vow. Landor upheld that pledge for nearly 20 years, until he was nearly finished with a five-month prison sentence in Louisiana.
For the first four months of his incarceration, the two facilities where Landor was housed allowed him to keep his hair long or under a “rastacap.” But that changed after Landor was transferred to the Raymond Laborde Correctional Center for the final three weeks of his sentence. Once there, Landor told an intake guard that he was a practicing Rastafarian and handed over proof of his religious accommodations, as well as a copy of a 2017 decision from the 5th Circuit that found Louisiana’s policy of cutting Rastafarians’ hair violated RLUIPA, according to court filings.
But two guards ultimately handcuffed Landor to a chair, held him down and had his head shaved, according to papers filed with the Supreme Court.
Landor filed a lawsuit against the prison officials after he was released and brought numerous claims, including under the RLUIPA. But a federal judge agreed to dismiss the case, finding that the law does not allow for damages against individual state officials.
A three-judge panel of judges on the 5th Circuit affirmed that decision, ruling that while it “emphatically” condemned Landor’s treatment, a prior decision in the circuit required it to hold that he could not seek money damages from officials in their individual capacities for violations of RLUIPA.
The full 5th Circuit refused to reconsider the case, with 11 judges voting not to rehear it and six voting in favor.
The case follows a Supreme Court decision from December 2020 in which it unanimously held that the Religious Freedom Restoration Act, RLUIPA’s sister statute, allows litigants to obtain money damages against federal officials in their individual capacities.
Lawyers for Landor argued that Congress enacted the two laws to provide meaningful protection for religious liberty, and denying litigants the opportunity to seek damages for violations of RLUIPA would render that promise empty.
Louisiana officials said in court papers that the allegations raised in Landor’s appeal are “antithetical to religious freedom and fair treatment of state prisoners,” and condemned them “in the strongest possible terms.” But they urged the Supreme Court to turn away his appeal and said the state amended its prison grooming policy to prevent other inmates from being treated as Landor was.
The justices will hear arguments in its next term, which begins in October, with a decision expected by the summer of 2026.
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