Supreme Court Rules Against Inmate in Religious Hair Dispute Lawsuit

WASHINGTON – The U.S. Supreme Court ruled Tuesday that a former Louisiana inmate cannot sue individual prison officials for damages after they shaved his head, despite his religious objections. The 6-3 decision in *Landor v. Louisiana Department of Corrections* found that the federal law intended to protect the religious rights of prisoners does not authorize Damon Landor's lawsuit seeking damage payments from the officials.

Justice Neil Gorsuch, writing for the majority, stated that Congress's power under the Constitution's spending clause, which underpins the religious rights law, does not include the authority to regulate in a way that allows such lawsuits without a clear agreement. Gorsuch wrote that spending clause statutes can bind only those who "voluntarily and knowingly undertake obligations by agreement with the federal government."

Justice Ketanji Brown Jackson authored a dissenting opinion, joined by Justices Sonia Sotomayor and Elena Kagan. She argued that the majority's ruling would leave prisoners like Landor seeking "remediless" when their religious freedoms in state prisons are violated. Jackson stated that state-empowered prison officials would have "little incentive to abide by federal law" under this precedent.

The dispute originated in December 2020 at the Raymond Laborde Correctional Center. Landor, a Rastafarian, had maintained long hair for nearly two decades as part of his faith. He had previously been permitted to keep his hair long or covered at other correctional facilities.

Upon his transfer to the Raymond Laborde Correctional Center, Landor informed a prison guard of his Rastafarian beliefs and presented a copy of a federal appeals court ruling. This ruling stated that Louisiana's policy of cutting Rastafarian hair violated the Religious Land Use and Institutionalized Persons Act (RLUIPA) and other religious accommodation provisions. Landor alleges the guard disregarded the document, and a warden subsequently ordered officers to shave his head while he was handcuffed.

Landor filed a federal lawsuit in 2021, citing a RLUIPA provision allowing individuals to sue government entities for "appropriate relief." Lower courts dismissed his case, concluding that RLUIPA does not permit private individuals to seek monetary damages. Landor appealed to the Supreme Court.

Gorsuch’s 18-page majority opinion explained that Congress enacted RLUIPA under its spending clause power, which allows it to provide for the "general Welfare of the United States." While this allows Congress to set conditions for federal funds, Gorsuch reasoned that it can only impose sanctions if recipients have "knowingly and voluntarily consented to those sanctions."

He noted that the Louisiana Department of Corrections did not dispute its agreement to be sued by private plaintiffs under RLUIPA as a condition for receiving federal funds. However, Gorsuch emphasized that Landor did not contend that the individual prison officials named in his lawsuit had "voluntarily and knowingly consented to answer private suits under RLUIPA." This absence of consent meant the lawsuit against them could not proceed. Gorsuch rejected the argument that officials implicitly consented due to their employment with a federally funded entity.

Gorsuch also addressed Landor’s argument referencing the Necessary and Proper Clause. Landor contended, and Jackson’s dissent supported, that this clause would allow Congress to authorize lawsuits against individual officials as a "necessary and proper" means to achieve RLUIPA's goal of protecting religious freedom. Gorsuch countered that the focus should be on whether such a cause of action is necessary and proper to Congress's spending power, not merely to RLUIPA's policy objectives. He concluded it was not.

In her 29-page dissent, Jackson criticized the majority’s "novel consent requirement." She stated that the ruling means "Spending Clause legislation may not make anybody liable without their express consent." Jackson argued that prison officials, unlike their employers, have not directly accepted federal funds, thus, on the majority's view, they have not consented to be sanctioned for not following federal law. Jackson asserted that the opinion "jettisons 'a long line of this Court’s precedents'" regarding Congress's ability to use its spending power beyond direct recipients of federal funds.