Supreme Court to Review Case of Rastafarian Inmate Whose Dreadlocks Were Forcibly Removed in Louisiana Prison
Supreme Court to Review Case of Rastafarian Inmate Whose Dreadlocks Were Forcibly Removed in Louisiana Prison
Damon Landor, a Rastafarian inmate, is appealing to the Supreme Court to determine whether he can sue individual Louisiana prison officials for damages after his dreadlocks, worn for religious reasons, were forcibly cut off while he served a five-month sentence in 2020 for drug possession.
Landor had been growing his dreadlocks for nearly two decades. For the first four months of his sentence, he was housed in facilities that accommodated his long hair or allowed him to wear a rastacap. However, during his transfer to the Raymond Laborde Correctional Center with three weeks remaining in his sentence, prison officials, despite his explanation of his Rastafarian beliefs and presentation of proof of past religious accommodations, ordered his hair to be shaved. He was handcuffed to a chair and forcibly shaved against his will. He had previously presented a copy of a court ruling supporting religious accommodation of dreadlocks, but this was discarded by a guard.
Landor subsequently filed a lawsuit citing the Religious Land Use and Institutionalized Persons Act (RLUIPA), which protects the religious rights of prisoners. The lawsuit names the warden, the head of the Louisiana corrections department, and the guards involved. A district court dismissed the case, ruling that RLUIPA does not provide an avenue for seeking damages against individual state officials. An appeals court upheld this decision. Landor’s legal team argues that without the possibility of monetary damages, there is no effective incentive for prison officials to comply with RLUIPA.
The Louisiana Attorney General, Elizabeth Murrill, opposes the suit, arguing that allowing such damages would exacerbate existing prison staffing shortages and potentially worsen prison conditions. The state emphasizes that it has amended its prison grooming policy to prevent similar incidents. The state also argues that Congress has had ample opportunity to amend RLUIPA to explicitly allow for damages if it had intended to do so.
Landor’s case has garnered support from numerous religious organizations, including the Christian Legal Society, Agudath Israel of America, and over 30 other faith-based groups, who have filed amicus curiae briefs. The Trump administration also filed a brief in support of Landor’s case. These groups argue that monetary damages are often the only effective remedy for religious rights violations in prisons, particularly given that many inmates are released or transferred before their claims are resolved.
The Supreme Court’s decision in a 2020 case involving a similar federal law allowed Muslim men to sue FBI agents for damages related to religious rights violations. While the appeals court judges expressed sympathy for Landor’s situation, they deferred to the Supreme Court to determine whether the precedent from the 2020 case applies to state prison workers under RLUIPA.
Landor’s legal team contends that without the possibility of damages, the state’s commitment to preventing future incidents is meaningless. They argue that without this recourse, prison officials could disregard the amended policy with impunity. The Supreme Court will hear arguments in the case during its next term, beginning in October.
The case raises broader questions about the interpretation of RLUIPA and the protection of religious freedom for minority faiths within the prison system. The lack of specific guidance within RLUIPA regarding “appropriate relief” has led to varying interpretations, highlighting the need for clearer legal definitions and enforcement mechanisms to protect the religious rights of incarcerated individuals.
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