The U.S. Supreme Court rejected an attempt by a Rastafarian inmate to hold Louisiana prison guards personally liable for violating his religious rights by forcibly shaving his dreadlocks. In a 6-3 decision, the Court held that the Religious Land Use and Institutionalized Persons Act (RLUIPA) does not allow lawsuits for monetary damages against state and local government officials in their individual capacities—even when the officials work for institutions that receive federal funding. Justice Neil Gorsuch, writing for the majority, explained that RLUIPA is an exercise of Congress’s Spending Power. By accepting federal funds, states consent to liability under the law. Individual prison guards and officials, however, do not automatically consent simply by working for the state. Unless they “voluntarily and knowingly” agreed to be held personally liable, they cannot be sued under RLUIPA in their personal capacity.
The case involved Damon Landor, a devout Rastafarian who adheres to the Nazarite Vow that prohibits cutting one’s hair. In 2020, guards at Raymond Laborde Correctional Center in Cottonport, Louisiana, handcuffed him to a chair and shaved his head against his strong objections. While the Court ruled that Landor cannot seek damages from the 10 guards or from the former warden under RLUIPA, the decision leaves open other avenues, namely federal claims against the Louisiana Department of Corrections and Public Safety as the institution/employer and state-law claims against the individual guards. This decision limits the scope of RLUIPA lawsuits against public employees while preserving institutional accountability for religious accommodation violations in prisons and other publicly funded facilities.
