Imagine holding a federal court order in your hand, showing it to a prison guard, and watching him toss it directly into the trash. That is exactly what happened to Damon Landor in 2020 at the Raymond Laborde Correctional Center in Louisiana. Landor, a devout Rastafarian who had grown his knee-length dreadlocks for nearly twenty years as part of a sacred vow, tried to prove that the facility had no legal right to cut his hair.
The guards did not care. They handcuffed Landor to a chair, held him down, and shaved his head completely bald.
The Supreme Court just ruled 6-3 that Landor cannot sue those individual prison guards for money damages. Even though the justices openly condemned the behavior of the guards, the conservative majority ruled that the specific civil rights law protecting incarcerated people does not allow individuals to be held personally liable for financial payouts.
It is a striking decision. For a court that has spent recent terms expanding religious liberty protections for football coaches, Christian web designers, and religious schools, this ruling draws a hard, technical line at the prison gates.
The Absolute Immunity Loophole inside State Prisons
To understand why Landor walked away empty-handed, you have to look at the specific tool his lawyers used to sue. They relied on a 2000 federal statute called the Religious Land Use and Institutionalized Persons Act, commonly known as RLUIPA.
Congress passed RLUIPA to protect the religious rights of people inside institutions like jails and prisons. If a state prison takes federal funding, it has to agree to follow this law.
Writing for the 6-3 majority, Justice Neil Gorsuch looked at the case through the lens of contract law rather than basic human rights. Because RLUIPA was passed under the Constitution's Spending Clause, the law operates basically like a contract between the federal government and the state. The state prison system gets federal cash, so the prison agrees to follow the rules.
But individual guards? They never signed that contract.
Gorsuch wrote that Congress lacks the regulatory authority to impose direct financial liability on individual officers without their explicit consent. Because those Louisiana guards never personally agreed to answer lawsuits under RLUIPA, Landor cannot sue them for damages any more than you can sue someone for breaching a contract they never signed.
The ruling creates a massive accountability gap. Because Landor had already completed his short five-month sentence for drug possession by the time the legal gears started turning, he could no longer sue for an injunction to stop them from cutting his hair. His hair was already gone. The only real remedy left to make things right or deter future abuse was financial damages. Now, that avenue is entirely blocked in federal court.
The Furious Dissent calling Out a Legal Trick
The Court's three liberal justices did not hold back. In a sharp 29-page dissent, Justice Ketanji Brown Jackson criticized the majority for treating civil rights legislation like a corporate transaction.
Jackson argued that the majority's effortless conflation of lawmaking and agreement-making completely trivializes federal statutes. By turning a major civil rights achievement into a mere contract, the court reduces crucial federal protections to nothing more than the wheelings-and-dealings of an especially wealthy private party.
The real-world consequence of this ruling is grim. If prison guards know they cannot be hit in their own pockets for violating an inmate's faith, what stops them from doing it anyway? Jackson warned that encroachments on prisoners' statutory rights will likely happen with fair frequency because state-empowered officials now have almost zero financial incentive to abide by federal law.
The Disconnect with Past Religious Liberty Rulings
What makes this decision especially frustrating for civil rights advocates is that the Supreme Court already looked at an almost identical law six years ago and ruled the exact opposite way.
In a 2020 case called Tanzin v. Tanvir, a group of Muslim men sued federal FBI agents who placed them on the No-Fly List because they refused to act as informants, violating their religious beliefs. The men sued under the Religious Freedom Restoration Act, which is the sister statute to the law used in Landor's case. In that case, the Supreme Court unanimously held that individual federal officials could face monetary damages for violating religious rights.
Why the flip-flop? It comes down to where the money comes from.
RFRA applies to the federal government and rests on broad congressional power. RLUIPA applies to state institutions and relies entirely on the federal power of the purse. Because the funding mechanisms are different, the conservative majority decided that the rules of accountability must be different too.
What This Means for Prisoners Rights Going Forward
If you are looking for immediate accountability inside state corrections facilities, the path just got incredibly narrow. The state of Louisiana claims it has already amended its prison grooming policies to ensure that nothing like Landor's experience happens again. But a change in internal policy is a far cry from a federal constitutional guarantee.
Civil rights attorneys and advocates will need to pivot quickly to navigate this shifting landscape.
- Shift Focus to State Courts: The Supreme Court's ruling bars individual damages under federal RLUIPA claims, but it does not kill the case entirely. Landor and others in his position still have the right to pursue claims under state constitutions or state tort laws regarding assault or intentional infliction of emotional distress.
- Target the Institutional Pocketbook Early: Since suing individual guards for federal damages is off the table, litigation must focus heavily on securing immediate emergency injunctions the moment a policy is violated, or proving systemic, institutional failures by the corrections department itself to clear the high bar of municipal liability.
- Lobbing for Legislative Fixes: The ball is now technically in Congress's court. If lawmakers want prison guards to be held personally accountable for forced head-shavings or other blatant religious violations, they will have to explicitly amend RLUIPA to state that individual capacity suits are allowed, bypassing the Spending Clause loophole the majority used to shield the guards.
