Supreme Court Rules Against Inmate Suing Over Forced Dreadlock Shaving

The US Supreme Court has ruled that a former Louisiana inmate cannot sue prison officials who forcibly shaved his dreadlocks in violation of his Rastafarian faith.

In a 6-3 ruling, the top court said the prisoner, Damon Landor, was not entitled to monetary damages under a federal religious freedom law as it did not apply to individual officials.

The justices said state employees did not consent to face lawsuits in their personal capacities when Congress passed the Religious Land Use and Institutionalized Persons Act (RLUIPA) in 2000.

The ruling marks a departure from a series of recent Supreme Court decisions, in which the justices have generally sided with religious-liberty claims.

Growing uncut, uncombed hair into dreadlocks is a symbol of devotion and spiritual growth for Rastafarians.

In a statement to USA Today, Landor said his dreadlocks are "a part of me and part of who I am".

"So when they cut off my hair, they cut off my crown," he said.

In the opinion on Tuesday, Conservative justices ruled against Landor, while three liberal justices dissented.

Justice Neil Gorsuch wrote that RLUPIA, which applies to local prisons that receive federal funding, does not allow for legal challenges against individual officials.

"Under the Spending Clause, Congress lacks regulatory authority to impose liability on them directly and must depend instead on consent," Justice Gorsuch wrote.

In her dissent, liberal Justice Ketanji Brown Jackson said the goal of RLUIPA was to "ensure that state and local prisons respect prisoners' right to religious exercise".

"Prisoners like Landor who suffer violations of their religious freedom in state prisons—no matter how blatant—will often be left remediless," Justice Jackson wrote.

In 2020, when Landor was serving time for a drug-related charge, officers handcuffed him to a chair and shaved his head after he argued it would violate his religious rights as a Rastafarian.

For the first four months that he was in prison, Landor was allowed to keep his dreadlocks, but was forcibly shaved after he was moved to Raymond Laborde Correctional Center for the last month of his sentence.

Landor told a guard there that he was Rastafarian and shared a copy of a ruling in which a court of appeals found that cutting the hair of a Rastafarian in prison violated RLUIPA.

The prison guards threw those papers in the trash before handcuffing him in a chair to cut his hair, court records show.

A federal judge and an appeals court ruled against Landor before the Supreme Court, arguing RLUIPA did not allow Landor to sue prison officials for damages as individuals.

In 2020, the Supreme Court had ruled that the Religious Freedom Restoration Act, a related statute from 1993, allowed individual damages suits against federal officials for religious liberty violations.

In that ruling, the top court had said that Muslim men who were placed on the government's no-fly list because they refused to serve as FBI informants could seek to hold federal agents financially liable.

But in Landor's case, Louisiana argued that RLUIPA should be treated differently because it governs state institutions.

While states agree to comply with federal rules when they accept federal funding, that agreement does not create a personal liability for individual prison employees, the state said.