The Supreme Court has ruled that a former Louisiana inmate cannot sue prison officials over the cutting of his dreadlocks, an action that violated his Rastafari religious beliefs. Despite condemning the incident involving Damon Landor, the justices decided that federal law does not permit lawsuits for monetary damages against individuals, even when religious rights are breached.
The court’s decision, passed in a 6-3 vote, aligns with previous lower court rulings that the Religious Land Use and Institutionalized Persons Act does not allow financial liability for those infringing on inmates’ rights. The court did not extend the reasoning of a 2020 ruling, which permitted Muslim men to sue over their inclusion on the FBI’s no-fly list under the Religious Freedom Restoration Act. In this case, the Justice Department had supported Landor’s position.
Justice Neil Gorsuch, writing for the majority, stated that nothing in the law provides for lawsuits against individual officers regarding prisoners’ religious rights. In dissent, Justice Ketanji Brown Jackson argued that the decision reduces incentives for state prison officials to comply with federal law, emphasizing the clear illustration of Congress’s intent behind such legislation. Her dissent was supported by two other liberal justices.
No defense was provided for the treatment Landor faced during his incarceration in 2020. When Landor entered the correctional system, he had a copy of an appeals court ruling that supported inmates’ religious rights to maintain dreadlocks. Initially, his beliefs were respected, but this changed upon his arrival at the Raymond Laborde Correctional Center. Court records indicate that a guard discarded his legal documentation, and guards forcibly cut his dreadlocks under the warden’s orders. After his release, Landor’s lawsuit was dismissed by lower courts, with the 5th U.S. Circuit Court of Appeals acknowledging his mistreatment but stressing the limitations of the law.
In response, Louisiana has modified its prison grooming policy. The Rastafari faith, rooted in 1930s Jamaica, combines Old Testament teachings with a desire for African repatriation. Its global spread was significantly influenced by musicians Bob Marley and Peter Tosh in the 1970s.