The United States Supreme Court ruled Tuesday that a former Louisiana inmate could not sue prison officials who cut off his dreadlocks for violating his Rastafari religious beliefs. In its decision, the Court held that individual correctional officers cannot be held personally liable for violations of federal law unless they themselves have agreed to be subject to such lawsuits.
The plaintiff, Damon Landor, a Rastafarian inmate, sought relief after prison officials forcibly shaved his head in violation of a prior court order. Followers of the Rastafarian faith do not cut their hair as part of a physical connection to God, known as the Nazarite vow. As a result, Landor had not cut his hair for 20 years and had allowed it to grow to his knees.
In a 6-3 decision split along ideological lines, with the conservative justices in the majority, the Supreme Court affirmed the Fifth Circuit Court of Appeals’ ruling in Landor v. Louisiana Department of Corrections (LDOC).
The case centers on the Religious Land Use and Institutionalized Persons Act (RLUIPA). The law protects the religious exercise of incarcerated individuals by preventing prisons from imposing substantial burdens on religious practices without a compelling governmental justification.
In 2017, the Fifth Circuit ruled that LDOC policies requiring Rastafarian inmates to cut their hair violated RLUIPA. Landor carried a printed copy of that ruling and personally showed it to correctional officers in 2020. The officers responded by throwing it in the trash.
When the prison warden requested documentation, Landor did not immediately have it available. Two correctional officers then took him to another room, handcuffed him to a chair and shaved his head, the lawsuit alleged.
After his release, Landor sued the Louisiana Department of Corrections and several officials in their individual capacities, seeking monetary damages under RLUIPA. The district court dismissed Landor’s RLUIPA claims against both the officers and LDOC. On appeal, Landor challenged only the dismissal of his claims against the officers in their individual capacities.
As a result, the cases before both the court of appeals and the Supreme Court concerned only Landor and the officers. Both courts dismissed his claims because the individual officers had no agreement with the federal government.
Notably, the Supreme Court did not address whether there was a violation of RLUIPA, but rather whether the officials could be held personally liable for such a violation. As such, the ruling concerned constitutional law governing Congress.
RLUIPA is based on the Spending Clause, a constitutional provision that allows the federal government to impose certain conditions on states and entities that receive federal funding.
Writing for the majority, Justice Neil Gorsuch explained that laws enacted under the Spending Clause function much like an agreement between the federal government and recipients of federal funds. Under that reasoning, Louisiana’s prison system accepted federal funds and thereby accepted the obligations imposed by RLUIPA. The prison employees were sued in their personal capacities and never entered into such an agreement with the federal government; therefore, according to the Court, they could not be held personally liable for damages under the statute.
Gorsuch added that Congress’s power to spend money does not amount to a general regulatory power. Consequently, obligations arising from Spending Clause legislation bind only those who voluntarily and knowingly accept the conditions attached to federal funding.
Landor and his attorneys argued that the officers receive salaries funded in part by federal money and, therefore, are themselves recipients of federal funds. The Court disagreed.
Justice Ketanji Brown Jackson wrote the dissenting opinion, joined by Justices Sonia Sotomayor and Elena Kagan. Jackson argued that the majority mistakenly treated RLUIPA as a contract rather than a federal statute. She also maintained that Congress had the authority to authorize damage actions against officials who violate the religious rights protected by the law.
The dissent warned that the ruling could make it more difficult to effectively protect those rights and could limit the reach of other federal statutes tied to federal funding.
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