U.S. Supreme Court
Rastafarian’s religious freedom suit against prison officials for cutting his hair wins Supreme Court review
The U.S. Supreme Court agreed Monday to decide whether a Rastafarian with religious objections to cutting his hair can seek money damages from Louisiana prison officials for strapping him down and shaving his head. (Photo from Shutterstock)
The U.S. Supreme Court agreed Monday to decide whether a Rastafarian with religious objections to cutting his hair can seek money damages from Louisiana prison officials for strapping him down and shaving his head.
The plaintiff, Damon Landor, said he is entitled to sue prison officials in their individual capacities under the Religious Land Use and Institutionalized Persons Act, which protects religious freedom in prisons and in land use. He said officials at the Raymond Laborde Correctional Facility in Louisiana cut his hair while ignoring the court decision that he carried establishing his right to keep his hair.
The 5th U.S. Circuit Court of Appeals at New Orleans ruled against Landor and denied rehearing in February 2024. A concurrence noted that prison officials “literally” threw into the trash can Landor’s 5th Circuit opinion holding that cutting Rastafarians’ hair violated the RLUIPA.
But the Supreme Court should resolve the clash between two of its opinions, one involving the RLUIPA and another involving the Religious Freedom Restoration Act—or the RFRA—the concurrence said.
Both laws authorize courts to grant “appropriate relief” for religious liberty violations. Landor’s cert petition described the law that he used to sue as a “sister statute” to the RFRA.
But the Supreme Court has ruled that sovereign immunity protects states from money damages under the RLUIPA while allowing damages claims by the RFRA against federal officials in their individual capacities.
Landor argued that the RLUIPA’s promise is “empty” without a damages remedy.
“No relief is not ‘appropriate relief,’” the cert petition argued.
SCOTUSblog, Bloomberg Law, Law360 and the New York Times are among the publications covering the cert grant.
The case is Landor v. Louisiana Department of Corrections and Public Safety.
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