US Supreme Court blocks Rastafarian man's lawsuit over forced head-shaving in prison

The Supreme Court ruled 6-3 on Tuesday that Damon Landor, a Rastafarian former Louisiana inmate, cannot seek money damages from individual prison officials after guards forcibly shaved his dreadlocks in 2020.

The decision narrows a possible remedy under the Religious Land Use and Institutionalized Persons Act, or RLUIPA, even in a case where the court accepted that Landor may have suffered a serious violation of his religious rights.

The justices did not decide whether the shaving itself was lawful. Instead, they focused on a narrower question: whether RLUIPA lets a prisoner recover damages from officials in their individual capacities.

The court said it does not.

The prison encounter

Landor’s case grew out of his transfer to Raymond Laborde Correctional Center in Louisiana. According to the reporting underlying the case, he told staff about his Rastafarian faith and his objection to cutting his hair.

Rastafarians often treat dreadlocks as an expression of religious observance. Landor also showed prison staff a copy of an earlier Fifth Circuit ruling that had protected Rastafarian hair practices under federal law, according to reporting.

The reporting says a guard threw that ruling in the trash before Landor was restrained and his dreadlocks were shaved.

That sequence turned an individual prison incident into a broader test of how far federal religious-liberty law reaches when a prisoner seeks compensation after the fact.

Why the lawsuit mattered

RLUIPA protects the religious exercise of people confined in institutions such as prisons and jails. It is often used when an inmate says a policy or staff action burdened religious practice.

Landor’s lawsuit asked whether officials who violate that statute can be ordered to pay damages personally. That remedy matters because money damages can be the most direct way to hold individual officers financially accountable for a completed rights violation.

The Supreme Court’s answer was no.

That holding leaves Landor without the damages route he sought, even though the alleged violation involved a core religious practice and a use-of-force response by prison staff.

How the case reached the court

Lower courts had dismissed Landor’s suit on the ground that RLUIPA does not create a damages remedy against individual officials. The Supreme Court took the case after that ruling.

According to prior reporting, the justices agreed to hear the dispute in June 2025 and argued it during their November sitting.

The case also drew attention because the Justice Department supported Landor’s position in the Supreme Court.

Louisiana, for its part, said it had since amended its prison grooming policy after the incident.

The ruling and dissent

On Tuesday, the court sided with Louisiana prison officials in a 6-3 decision. Justice Ketanji Brown Jackson dissented, according to Associated Press reporting.

The ruling does not erase the underlying allegations. It does, however, close off one legal path that prisoners and their lawyers have treated as important in religious-accommodation cases.

The Court’s distinction also matters because it separates RLUIPA from the Religious Freedom Restoration Act. In Tanzin v. Tanvir, the Court previously allowed damages claims against federal officials under RFRA. Tuesday’s ruling makes clear that the RLUIPA remedy question is different.

Broader impact

The case is likely to be cited in future prison-rights disputes and other spending-clause cases involving religious accommodation.

For prison systems, the decision reduces exposure for individual officers. For prisoners asserting religious-liberty claims, it means one of the strongest financial remedies is no longer available under this statute.

The ruling also highlights a recurring gap in prison law: a court may recognize that a rights violation occurred, but still leave a plaintiff without a money remedy after the harm is complete.

Lawyers and religious-liberty groups are expected to study the opinion closely for any narrower reasoning or signals about future claims. For now, the headline result is straightforward: under RLUIPA, the Supreme Court says prisoners cannot seek money damages from individual prison officials for this kind of alleged violation.