Supreme Court Rules Against Rastafarian Inmate
In a 6-3 decision in Landor v. Louisiana Department of Corrections and Public Safety, the U.S. Supreme Court held that the Religious Land Use and Institutionalized Persons Act (RLUIPA) does not permit money-damages suits against state prison officers in their personal capacities when those officers have not consented to such liability. The ruling affirms the Fifth Circuit and leaves open whether damages may be sought against prison systems themselves.
Supreme Court on Tuesday rejected a former Louisiana inmate’s claim to seek money damages from individual prison officers under the Religious Land Use and Institutionalized Persons Act (RLUIPA), in a 6-3 opinion authored by Justice Neil Gorsuch and joined by Chief Justice John Roberts and Justices Clarence Thomas, Samuel Alito, Brett Kavanaugh and Amy Coney Barrett.
Louisiana Department of Corrections and Public Safety, involved Damon Landor, a Rastafarian whose faith requires him to keep his hair uncut. Landor said that in 2020, while in state custody near the end of his sentence, intake officers at a new facility ignored a copy of Ware v. Louisiana Department of Corrections — a Fifth Circuit decision protecting Rastafarian detainees from forced haircuts — threw the paper away and shaved his head.
Landor sued under RLUIPA seeking money damages against the Department of Corrections and individual officers in their personal capacities. Lower courts dismissed his RLUIPA damage claims. The Fifth Circuit held that RLUIPA, enacted under Congress’s Spending Clause, does not permit suits for damages against individual officers who did not voluntarily agree to the federal funding conditions.
The Supreme Court agreed, explaining that Spending Clause statutes bind only those who have “voluntarily and knowingly” taken on obligations by contract with the federal government, and the individual officers had not done so. The majority explicitly declined to resolve whether RLUIPA permits money damages against funding recipients such as state prison systems.
Justice Ketanji Brown Jackson dissented, joined by Justices Sonia Sotomayor and Elena Kagan. The dissent framed RLUIPA as a statute meant to ensure respect for prisoners’ religious exercise and warned that barring personal-capacity damage suits can leave inmates without meaningful remedies when officials violate those protections.
Justice Jackson contrasted RLUIPA with the Religious Freedom Restoration Act, under which the Court has recognised personal-capacity remedies in some contexts. For British Virgin Islands residents, the ruling is important less for its direct legal effect — RLUIPA is a U.S. federal law and does not apply to the BVI — and more for its broader implications.
The decision underscores limits on suing individual officials for damages under laws tied to federal spending, and highlights the practical gap that can exist between rights and remedies. In the BVI, where Rastafari communities and other faith groups have longstanding cultural and religious practices, the case is a reminder for prison authorities and policymakers to ensure clear, respectful procedures for religious accommodations and for the public to be aware of local avenues for redress, including administrative complaints, local human-rights protections and civil claims against institutions.
The decision leaves intact the Fifth Circuit’s dismissal of Mr. Landor’s RLUIPA damages claim against the officers and narrows one path for monetary recovery while leaving open other legal avenues against institutions themselves.
Primary source: VINO