Supreme Court rules against Rastafarian prisoner who sued over shaved dreadlocks

A divided Supreme Court ruled against a Rastafarian man who wanted to sue Louisiana prison officials for monetary damages after they cut his dreadlocks.

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Justice Neil Gorsuch authored Tuesday’s majority opinion for the court’s six Republican appointees, writing that a federal law designed to protect religion does not permit plaintiffs to sue nonconsenting state employees in their private capacities for damages.

Justice Ketanji Brown Jackson’s dissent for the three Democratic appointees said the majority misconstrued the Constitution and ignored precedent while leaving state prisoners whose religious rights were violated struggling to vindicate them.  

When Damon Landor was incarcerated in Louisiana in 2020, he carried with him a copy of a federal appeals court ruling that upheld an inmate’s right to keep dreadlocks. But he said a guard threw his papers in the trash and summoned the warden, Marcus Myers, who asked Landor to provide proof from his sentencing judge corroborating his religious beliefs. When Landor couldn’t immediately do so, he said two guards brought him to another room, chained him to a chair and shaved his head.

He sued the Louisiana Department of Corrections, the prison, Myers and the department’s secretary, James LeBlanc, in their individual and official capacities. He cited the federal law from the trashed opinion, the Religious Land Use and Institutionalized Persons Act, or RLUIPA.

Myers and LeBlanc argued Landor’s RLUIPA claims were barred by precedent in the U.S. Court of Appeals for the 5th Circuit, which hears appeals from Louisiana. It was the 5th Circuit that issued the trashed 2017 ruling.

A 5th Circuit panel sided with the government defendants. The appellate judges wrote that they were bound by their precedent even while they “emphatically condemn the treatment that Landor endured.” When the circuit court declined to revisit the matter, another group of its judges said that “only the Supreme Court can answer” whether Landor can seek damages against individual officials.

“This Court should take up that call,” Landor’s lawyers wrote to the justices, who agreed to review his case. It takes four justices to grant review of a petition.

The Trump administration supported Landor’s appeal, citing the need to hold officials accountable for burdening the free exercise of religion.

Rejecting Landor on Tuesday, Gorsuch said that under the Constitution’s spending clause, Congress lacks authority to impose liability on the officers directly and must therefore depend on consent.