US Supreme Court Denies Lawsuit Against Prison Guards Who Cut Rastafarian Inmate's Dreadlocks

The United States Supreme Court ruled 6-3 that a former Louisiana inmate cannot seek financial damages from individual prison guards who forcibly shaved his dreadlocks. The majority, led by Justice Neil Gorsuch, held that the Religious Land Use and Institutionalized Persons Act (RLUIPA) does not permit lawsuits against prison employees in their personal capacity. The court reasoned that since the law focuses on state entities accepting federal funding, individual officers did not legally consent to be held personally liable under the statute.

The plaintiff, Damon Landor, was serving a prison sentence in 2020 when guards forcibly shaved his head despite his objections based on his Rastafarian faith. Before the incident, Landor had presented documents from a previous court ruling that identified the cutting of a Rastafarian inmate’s hair as a violation of federal law. Despite this, prison officials proceeded with the shaving, leading Landor to pursue litigation for religious freedom violations.

The decision marks a significant boundary for religious liberty claims within the carceral system. In her dissent, Justice Ketanji Brown Jackson argued that the ruling effectively leaves prisoners without a remedy for even blatant constitutional violations, potentially removing the incentive for prison staff to respect religious exercise. While the majority did not contest that Landor’s religious rights were violated, the procedural barrier established by this ruling creates a substantial hurdle for individuals seeking to hold specific officials accountable for their actions.