US top court says Rastafarian man cannot sue prison guards who cut his dreadlocks



A man with dreadlocks
Growing uncut, uncombed hair into dreadlocks is a symbol of devotion and spiritual growth for Rastafarians


In a 6‑3 decision, the United States Supreme Court denied former Louisiana inmate Damon Landor a remedy for being forcibly shaved inside prison, holding that the Religious Land Use and Institutionalized Persons Act (RLUIPA) does not license damages against individual prison staff.


Justice Neil Gorsuch wrote that RLUIPA’s application is limited to entities receiving federal funding, and that it does not create personal liability for the guards who carried out the haircut. He cited the Spending Clause to explain Congress’s inability to impose direct financial responsibility on individual employees.


Justice Ketanji Brown Jackson dissented, underscoring that RLUIPA’s purpose is to ensure state and local prisons respect inmates’ rights to religious exercise. She argued that without remedies, inmates who suffer blatant violations could be left without recourse.


Landor’s ordeal began in 2020 when, after spending time on a drug‑related charge, prison officials handcuffed him to a chair and shaved his head, despite his claim that it would violate his Rastafarian faith. For the first four months he was allowed to keep his dreadlocks, but a final month at Raymond Laborde Correctional Center saw the forced shaving after he presented evidence from a previous appellate ruling that cutting the hair of a Rastafarian violated RLUIPA.


The guards discarded Landor’s legal briefs before cutting his hair, illustrating a blatant disregard for the law’s protective intentions. Lower court decisions had rejected his claim, agreeing that individuals cannot sue for damages under RLUIPA against personnel. The Supreme Court’s ruling confirms that sentiment, differentiating the act from the older Religious Freedom Restoration Act which allowed individual damages suits against federal officials.


While the decision may appear as a setback for religious liberties in the penal system, it also reflects the court’s broader trend of tightening the boundaries of what federal statutes cover when applied to state institutions.