US Supreme Court: Rastafarian inmate cannot sue prison guards for cutting dreadlocks

The US Supreme Court has ruled 6-3 that a former Louisiana inmate, Damon Landor, cannot sue prison officials who forcibly shaved his dreadlocks, violating his Rastafarian faith. The court held that the Religious Land Use and Institutionalized Persons Act (RLUIPA), passed in 2000, does not allow monetary damages claims against individual state employees because they did not consent to being sued in their personal capacity.

This decision marks a departure from recent Supreme Court rulings that generally favored religious liberty claims. In 2020, while serving a drug-related sentence, Landor was handcuffed to a chair and had his head shaved despite arguing it would violate his religious rights as a Rastafarian. 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." For Rastafarians, growing uncut, uncombed hair into dreadlocks symbolizes devotion and spiritual growth.

Conservative justices ruled against Landor, while three liberal justices dissented. Justice Neil Gorsuch wrote that RLUIPA, which applies to local prisons receiving federal funding, does not authorize lawsuits against individual officials. "Under the Spending Clause, Congress lacks regulatory authority to impose liability on them directly and must depend instead on consent," 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."