When they cut off my hair, they cut off my crown
Damon Landor's religious freedom claim failed because the court said Congress didn't intend RLUIPA to create personal liability for individual state prison officials. Prison guards handcuffed Landor and shaved his head despite him providing court documents showing such actions violated his Rastafarian faith protections.
- Supreme Court ruled 6-3 that RLUIPA does not allow damages suits against individual state prison officials
- Damon Landor was handcuffed and forcibly shaved in 2020 despite providing court documents proving the violation
- Guards discarded Landor's legal papers before cutting his hair at Raymond Laborde Correctional Center
- Justice Jackson warned prisoners with religious violations in state prisons will often have no legal remedy
The US Supreme Court ruled 6-3 that a former Louisiana inmate cannot sue prison guards who forcibly cut his dreadlocks, finding RLUIPA doesn't allow damages against individual state employees.
Damon Landor sat handcuffed to a chair while prison guards shaved his head. It was 2020, near the end of his sentence at Raymond Laborde Correctional Center in Louisiana, and he had just told them he was Rastafarian—that his dreadlocks were sacred, a symbol of spiritual devotion and growth in his faith. He even handed them court papers proving it. A federal appeals court had already ruled that cutting a Rastafarian's hair in prison violated federal religious freedom law. The guards threw the papers away and cut anyway.
On Tuesday, the US Supreme Court decided Landor cannot sue those guards for money damages. In a 6-3 decision, the justices ruled that the Religious Land Use and Institutionalized Persons Act, passed by Congress in 2000, does not allow prisoners to hold individual state employees personally liable for religious violations. The law protects religious exercise in prisons that receive federal funding, the majority said, but it does not create a legal pathway for inmates to recover damages from the officials who harmed them.
Justice Neil Gorsuch, writing for the conservative majority, framed the question narrowly: Congress, he argued, lacks the power under the Constitution's Spending Clause to impose direct liability on state employees. When states accept federal money, they consent to follow federal rules—but that consent does not extend to making individual prison workers financially responsible for violations. The logic was technical, but the consequence was concrete. Landor had no remedy.
Landor himself understood what was lost. "My dreadlocks are a part of me and part of who I am," he told USA Today. "So when they cut off my hair, they cut off my crown." For Rastafarians, the uncut, uncombed hair growing into locks represents not vanity but faith—a visible commitment to spiritual principles. The act of shaving him was not incidental punishment. It was, from his perspective, an erasure.
The case had traveled through the lower courts already. A federal judge and an appeals court had both ruled against Landor on the same grounds the Supreme Court adopted: RLUIPA, they said, simply did not authorize damages suits against individual officials. But the Supreme Court's decision marked a sharp turn from its recent trajectory. In 2020, the justices had ruled that a related statute—the Religious Freedom Restoration Act of 1993—did allow individual damages suits, at least against federal officials. Muslim men placed on the no-fly list because they refused to become FBI informants could hold federal agents financially liable. Why not Landor?
Louisiana's answer was that state prisons are different. The state argued that RLUIPA governs state institutions differently than the other law governs federal ones. When a state accepts federal funding, it agrees to comply with federal rules, but that agreement does not create personal liability for individual employees. The Supreme Court majority accepted this distinction.
Justice Ketanji Brown Jackson dissented, joined by two other liberal justices. She wrote that RLUIPA's entire purpose was to "ensure that state and local prisons respect prisoners' right to religious exercise." But under the majority's logic, she warned, "prisoners like Landor who suffer violations of their religious freedom in state prisons—no matter how blatant—will often be left remediless." A prisoner could have court papers in hand proving his rights, hand them to a guard, and watch that guard destroy them and cut his hair anyway—and have no legal recourse. The law would protect his right in theory while offering no protection in practice.
The ruling sits uneasily with the Supreme Court's recent pattern of expanding religious liberty protections. In recent years, the justices have sided with religious claimants across a range of cases. But this decision, by a 6-3 margin, suggests the court's commitment to religious freedom has limits—particularly when the question is not whether a right exists, but who must pay when it is violated.
Citas Notables
My dreadlocks are a part of me and part of who I am. So when they cut off my hair, they cut off my crown.— Damon Landor, former inmate
Prisoners like Landor who suffer violations of their religious freedom in state prisons—no matter how blatant—will often be left remediless.— Justice Ketanji Brown Jackson, dissenting
La Conversación del Hearth Otra perspectiva de la historia
Why does it matter whether Landor sues the individual guards versus the state itself?
Because individual officials have no money. The state has resources. If you can only sue the state, the state might settle or pay a judgment. But if you can't sue anyone—because the state has immunity and the individuals can't be sued—then nobody pays. Landor gets nothing.
But Congress passed RLUIPA to protect religious freedom in prisons. Didn't they intend for people to have a remedy?
That's Jackson's argument in dissent. She says yes—the whole point was to protect prisoners' rights. But the majority says Congress didn't explicitly say individual officials could be sued for damages. And without explicit language, the Court won't infer it.
So the law protects the right but not the person whose right was violated?
Exactly. Landor's right to keep his dreadlocks was real. A court had already said so. But when the right was violated, he had no way to hold anyone accountable. The law exists; the remedy doesn't.
Is this surprising given what the Court did in 2020 with the no-fly list case?
Very. In that case, the Court said a similar religious freedom law did allow damages against federal officials. So why not state officials? The majority's answer is that states are different—they have sovereign immunity. But that distinction feels thin when you're the person whose hair was cut.
What happens to Landor now?
He's out of prison. His dreadlocks are gone. He has no legal claim. The guards face no consequences. And the next Rastafarian prisoner in Louisiana knows the same thing could happen to them.