Supreme Court tells Rastafarian he can’t sue prison officials after his hair was forcibly cut
Justices split along ideological lines with conservatives rejecting ex-prisoner’s claim
The U.S. Supreme Court has strengthened religious liberty in recent years, but that trend was at least paused today as the court ruled 6-3 that a Rastafarian whose hair was forcibly cut by Louisiana prison guards in 2020 cannot sue prison officials.
The prisoner, Damon Landor, had filed suit under the Religious Land Use and Institutionalized Persons Act, a federal law that requires states to provide, among other things, various religious-liberty protections in prisons that receive federal funds. Because other legal avenues weren’t available to him, Landor filed his suit against prison guards and other prison officials in their personal capacities, but that attempt was rebuffed in lower courts. RLUIPA is a companion law to the more widely known Religious Freedom Restoration Act.
Both RLUIPA and RFRA are intended to protect religious rights that are beyond those guaranteed by the U.S. Constitution. So today’s ruling focused on technical issues related to how RLUIPA should be interpreted rather than on constitutional issues.
The court ruling was divided along ideological lines, with the six conservative justices siding with prison employees and the liberals siding with Landor. Ironically, Landor had the support of the Donald Trump administration as well as two law firms, the Becket Fund for Religious Liberty and the American Center for Law and Justice, known for their support of Christian conservatives, among others, in religious-freedom cases.
The case was Damon Landor v. Louisiana Department of Corrections and Public Safety. For details of the incident in which Landor’s hair was cut, see this earlier article.
Justice Neil Gorsuch, writing the majority opinion, said that well-settled contract law determines the case’s outcome. Because the prison officials weren’t the ones who made an agreement with the federal government, he wrote, there was no contract in which they agreed to assume liability for violation of federal law:
Before us, LDOC [the Louisiana Department of Corrections] does not dispute that it is a recipient of federal funds. It does not question that it has agreed to answer certain RLUIPA suits as a condition of accepting those funds. But as it comes to us, this case does not involve claims against LDOC. It involves only claims against individuals in their personal capacities. And Mr. Landor does not allege that any of those individuals has entered any agreement with the federal government, let alone that any of them has voluntarily and knowingly consented to answer private suits under RLUIPA.
To know that is enough to know the Court of Appeals was correct. Mr. Landor does not have a federal RLUIPA cause of action against the officers.
The ruling drew an unusually strong rebuke from the minority, whose opinion was written by Justice Ketanji Brown Jackson. She noted that RFRA allows lawsuits against private parties, and the RLIUPA has identical wording. To base a ruling solely on contract law, is akin to “pulling this rabbit out of the hat” and ignoring “decades of precedent,” she wrote. She continued:
In the end, the Court reduces some of Congress’s greatest legislative achievements — federal laws that secure civil rights, environmental stability, healthcare, and more — to nothing more than the wheelings-and-dealings of an especially wealthy private party. Because I would not so trivialize a federal statute or the constitutional powers pursuant to which it was passed, I respectfully dissent.
This case was the last case focusing on religious freedom to be decided by the Supreme Court in its current term, which will probably end next week. Additionally, a pair of cases that have drawn strong interest from Christian conservatives, cases involving transsexual athletes, remain to be decided.