Supreme Court rules ex-convict cannot sue prison guards who cut off his dreadlocks
The US Supreme Court has ruled that a former inmate in Louisiana cannot sue prison officials who forced him to grow dreadlocks in violation of his Rastafarian faith.
In a 6-3 decision, the high court said the inmate, Damon Landor, was not eligible for financial compensation under the religious freedom law because it does not apply to individual officers.
The judges said federal employees were not allowed to face charges in their capacity when Congress passed the Religious Land Use and Institutionalized Persons Act (RLUIPA) in 2000.
The decision marks a departure from a series of recent Supreme Court decisions, in which justices have generally supported religious freedom claims.
The growth of uncut, untrimmed hair into dreadlocks is a sign of devotion and spiritual growth for Rastas.
In a statement to USA Today, Landor said her dreadlocks are “part of me and part of who I am”.
“So when they cut my hair, they cut my crown,” he said.
In Tuesday’s opinion, the conservative justices ruled against Landor, while three liberal justices dissented.
Justice Neil Gorsuch wrote that RLUPIA, which operates local jails that receive federal funding, does not allow legal challenges against individual officers.
“Under the Appropriations Clause, Congress does not have the regulatory authority to impose an obligation on them directly and must rely on consent,” Justice Gorsuch wrote.
In his dissent, Justice Ketanji Brown Jackson said the purpose of RLUIPA “is to ensure that state and local prisons respect the right of inmates to exercise their religion”.
“Prisoners like Landor whose religious freedoms are violated in state prisons—no matter how flagrant—will often go unremedied,” Justice Jackson wrote.
In 2020, when Landor was arrested on a drug-related charge, police handcuffed him to a chair and shaved his head after he protested that it would violate his religious rights as a Rasta.
During the first four months of his incarceration, Landor was allowed to keep his dreadlocks, but they were forcibly shaved after he was taken to the Raymond Laborde Correctional Center in the last month of his sentence.
Landor told a guard there that he was a Rastafarian and shared a copy of a ruling in which an appeals court found that cutting Rastafarian hair in prison violated RLUIPA.
Prison guards tossed the papers in the trash before handcuffing him to a chair to shave him, court records said.
A federal judge and an appeals court ruled against Landor before the Supreme Court, arguing that RLUIPA did not allow Landor to sue prison officials for damages as individuals.
In 2020, the Supreme Court ruled that the Religious Freedom Restoration Act, a related law from 1993, allowed individual injury suits against government officials for violations of religious freedom.
In that decision, the high court said that Muslim men who were put on the government’s no-fly list because they refused to be FBI informants could want to hold federal agents accountable.
But in Landor’s case, Louisiana argued that RLUIPA should be treated differently because it governs federal agencies.
Although states agree to comply with federal laws when accepting federal funding, that agreement does not create personal liability for individual prison employees, the state said.
