In a landmark 6-3 decision Tuesday, the U.S. Supreme Court ruled that state prison officials cannot be held personally liable for monetary damages under the Religious Land Use and Institutionalized Persons Act (RLUIPA), a federal law passed under Congress’s spending power to safeguard religious exercise behind bars.
The ruling in Landor v. Louisiana Department of Corrections and Public Safety reinforces constitutional boundaries on federal authority while preserving robust avenues for protecting faith in America’s prisons.
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Justice Neil Gorsuch authored the majority opinion, joined by Chief Justice John Roberts and Justices Clarence Thomas, Samuel Alito, Brett Kavanaugh, and Amy Coney Barrett.
The Court affirmed the Fifth Circuit’s dismissal of individual-capacity claims brought by former inmate Damon Landor, a Rastafarian who alleged prison officials violated his religious rights by shaving his dreadlocks shortly before his release.
Landor’s case stemmed from a 2020 incident at Louisiana’s Raymond Laborde Correctional Center.
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As a devout Rastafarian adhering to a Nazirite vow not to cut his hair, Landor had previously been allowed to maintain his dreadlocks at other facilities.
When transferred, he presented officials with a copy of a controlling Fifth Circuit decision confirming that Louisiana’s grooming policy burdened his religious exercise under RLUIPA.
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According to court filings, officials discarded the document, restrained him, and forcibly shaved his head – an action Landor described as a profound violation of his faith.
Landor sued the Louisiana Department of Corrections and Public Safety, Secretary James LeBlanc, the correctional center, and Warden Marcus Myers under RLUIPA and other claims, seeking money damages from the officials in their personal capacities.
Lower courts dismissed those individual claims, citing precedent that RLUIPA – enacted as a condition on federal prison funding – does not expose state employees to personal financial liability absent their knowing consent.
Writing for the majority, Justice Gorsuch emphasized a bedrock principle of constitutional law: When Congress acts under the Spending Clause, it may attach conditions to federal funds, but it cannot unilaterally create personal liability for state actors without clear, voluntary acceptance of those terms.
“Spending Clause legislation is in the nature of a contract,” Gorsuch explained.
Individuals must “voluntarily and knowingly” consent to suit in their personal capacities.
The Louisiana officials did not do so here, he argued.
The decision draws a clear line against federal overreach.
RLUIPA remains a powerful tool for inmates to secure injunctive relief and hold prison systems accountable in their official capacities.
But personal damages suits risk turning every policy disagreement into a personal jackpot for litigants—a concern conservatives have long raised about expansive interpretations of federal statutes.
Justice Ketanji Brown Jackson authored a sharp dissent, joined by Justices Sonia Sotomayor and Elena Kagan.
She argued the ruling leaves inmates like Landor without meaningful remedies for blatant violations, potentially undermining RLUIPA’s protective intent.
Jackson contended that identical language in the related Religious Freedom Restoration Act (RFRA) has been interpreted to allow damages, and RLUIPA should follow suit.
Conservative legal scholars counter that the dissent ignores the distinct constitutional footing of Spending Clause laws versus other federal powers.
Personal liability without consent risks deterring qualified individuals from public service and invites abuse in the litigious prison environment.
This ruling stands as a victory for originalist jurisprudence and states’ rights.
For religious freedom nationwide, the decision clarifies that protections under RLUIPA endure – just not through personal pocketbook hits.
Inmates retain the ability to sue the state entity, seek court orders to change policies, and pursue claims under the First Amendment via Section 1983.
Louisiana, for its part, has already updated its grooming policies to better respect religious practices, demonstrating that states can—and often do—address these issues without federal judicial micromanagement.
Attorney General Liz Murrill celebrated the outcome, noting Louisiana’s commitment to religious liberty through state law while praising the Court for rejecting personal liability.
“Ten federal courts of appeals had already reached this conclusion,” she said. “We condemn the alleged conduct but are grateful for clarity.”
This article may contain commentary which reflects the author’s opinion.
