Supreme Court Bars Rastafarian Prisoner’s Claim to Sue Guards Who Shaved His Dreadlocks

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

US Supreme Court jurisprudence has repeatedly protected religious liberty, yet on Tuesday a 6‑3 decision reversed that trend in the case of former Louisiana inmate Damon Landor. Landor sued prison officials who forcibly shaved his dreadlocks, claiming the act violated his faith under the Religious Land Use and Institutionalized Persons Act (RLUIPA). The Court ruled that RLUIPA does not provide a legal avenue to sue individual guards or other state employees for damages, leaving Landor without compensation.

Justice Neil Gorsuch, in the majority opinion, emphasized that the Spending Clause prevents Congress from imposing liability on individual low‑level prison workers and that RLUIPA only obligates state institutions that receive federal funds. The Court’s stance underscored that consent can not be imposed on individual officials.

Justice Ketanji Brown Jackson dissented, arguing that RLUIPA’s purpose is to ensure respect for inmates’ religious exercise. She warned that without individual liability, inmates can “be left remediless” when their faith is violated.

“So when they cut off my head, they cut off my crown” – Damon Landor. “The dreadlocks are part of me.”

Landor’s claim began in 2020 when he was handcuffed to a chair in a Louisiana facility and shaved after stating that it would violate his Rastafarian rights. The Incident occurred despite Landor’s presentation of an appellate ruling that the cutting of a Rastafarian’s hair in prison breached RLUIPA. The federal courts had dismissed his case earlier, noting that the Act did not authorize damages against individuals.

The Court’s decision highlights a granular legal distinction between federal statutes that allow damages against national officials, such as the Religious Freedom Restoration Act, and those that regulate state institutions. The outcome signals a narrowing of legal remedies for inmates in state settings, a development that stakeholders view as a setback for religious protection in prisons.