Landor v. Louisiana, Department of Corrections
Decision
Legal Issues
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Overview
Overview
Damon Landor is a devout Rastafarian who kept his dreadlocks for 20 years as a religious obligation, and three weeks before he was released from a Louisiana prison, guards handcuffed him to a chair and shaved his head, despite documentation of prior religious accommodations and a Fifth Circuit ruling specifically protecting Rastafarian inmates. The question before the Supreme Court is whether RLUIPA, the federal law protecting religious practice in prisons, gives inmates the right to sue government officials for money damages when that protection is violated. Landor has since been released, which means an injunction does him no good, and the damages question is the whole case. Argued November 2025, still pending as of May 2026, with the court appearing skeptical at oral argument.
The Facts
Facts
Landor, a prisoner in Louisiana, brought claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA) alleging that the Department of Corrections violated his right to religious exercise. He sought money damages against state officials. Lower courts dismissed the damages claim, finding that RLUIPA does not authorize money damages suits against states or state officials in their individual capacities.
The Issue
Issue
Whether the Religious Land Use and Institutionalized Persons Act authorizes a prisoner to seek money damages against individual state prison officials in their personal capacities for violations of the Act's protections for religious exercise.
The Rules
Rule
RLUIPA (42 U.S.C. § 2000cc-2(a)) permits 'appropriate relief against a government' for substantial burdens on religious exercise in institutions receiving federal funds. Enacted under the Spending Clause, RLUIPA's scope of remedies extends only to relief that states knowingly accepted as a condition of federal funding. Individual-capacity damages are available under 42 U.S.C. § 1983 for violations of federal rights under color of state law, but RLUIPA's distinct cause of action may not incorporate § 1983's full remedial scope.
The Application
Analysis
Landor argues RLUIPA's text authorizes 'appropriate relief against a government' and should include money damages against state officials in their individual capacities, consistent with Tanzin v. Tanvir (2020), which held the parallel Religious Freedom Restoration Act permits individual-capacity damages. RLUIPA and RFRA share the same relevant statutory language.
The Conclusion
Conclusion
The Court held 6-3 that RLUIPA, as a Spending Clause statute, cannot impose personal liability on individual state employees who never personally agreed to its terms as a condition of receiving federal funds. Damon Landor, a Rastafarian inmate whose head was forcibly shaved, cannot seek money damages directly from the officers under the religious freedom law.
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