Anchor
Supreme Court bars damages suits against prison officials under religious-rights law
Rule ChangesA Rastafarian man whose dreadlocks were shaved cannot collect money damages from the guards who did it, the Court ruled 6-3.
June 23rd, 2026: Court bars personal-capacity damagesNew here? Follow stories to track developments over time. Create a free account to get updates when stories you care about change.
Overview
Updated Jun 23Three weeks before his release, Louisiana prison guards handcuffed Damon Landor to a chair and shaved off the dreadlocks he had grown for nearly 20 years. He had handed them a court ruling saying his faith protected his hair. A guard threw it in the trash.
On June 23, 2026, the Supreme Court ruled 6-3 that Landor cannot sue those guards for money. The decision closes the one remedy that hits officials personally, and leaves many prisoners with rights on paper but no way to collect when those rights are broken.
Why it matters
A federal law promises prisoners the right to practice their faith. The Court just ruled that the officials who break that right usually can't be made to pay.
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Key Indicators
6-3
Vote
The Court split along ideological lines, with Gorsuch writing for the majority.
~20 years
Years Landor grew his hair
His Rastafarian vow not to cut his hair lasted roughly two decades before it was shaved.
2000
Year RLUIPA passed
Congress enacted the law unanimously to protect the religious practice of prisoners.
3 weeks
Time left on his sentence
Landor was near the end of a five-month drug sentence when his head was shaved.
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Supreme Court bars damages suits against prison officials under religious-rights law
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People Involved
Damon Landor
Former Louisiana inmate, plaintiff
Lost his bid for money damages; released from prison in 2020
Neil Gorsuch
Associate Justice, author of the majority opinion
Wrote for the 6-3 majority
Ketanji Brown Jackson
Associate Justice, author of the dissent
Dissented, joined by Sotomayor and Kagan
Organizations Involved
Supreme Court of the United States
Federal Court
Issued the 6-3 ruling
The nation's highest court, which decided that prison officials cannot be sued personally for money under RLUIPA.
Louisiana Department of Corrections and Public Safety
State Agency
Defendant; its officials shielded from personal damages
The state prison agency whose guards shaved Landor's head despite his religious objection.
Timeline
September 2000 June 2026
7 events
Latest: June 23rd, 2026 · 2 months ago
Tap a bar to jump to that date
-
Court bars personal-capacity damages
Latest RulingThe Supreme Court rules 6-3 that prison officials cannot be sued for money in their personal capacity under RLUIPA. Justice Gorsuch writes the majority; Justice Jackson dissents.
-
Supreme Court hears argument
LegalJustices question whether Congress can impose personal liability on officials through a spending-power law. The Court appears skeptical of Landor's position.
-
Fifth Circuit rejects Landor's damages claim
LegalThe appeals court rules RLUIPA does not authorize money damages against officials sued in their personal capacity. Several judges urge the Supreme Court to weigh in.
-
Court allows damages under sister law
LegalIn Tanzin v. Tanvir, the Supreme Court holds that the Religious Freedom Restoration Act allows money damages against federal officials sued personally. Landor argues RLUIPA should work the same way.
-
Guards shave Landor's head
IncidentWeeks from release, Landor is handcuffed to a chair and shaved at Raymond Laborde Correctional Center. A guard throws his court ruling in the trash.
-
Appeals court protects Rastafarian hair
LegalThe Fifth Circuit rules in a Louisiana case that shaving Rastafarian inmates' hair generally violates RLUIPA. Landor later hands guards a copy of this decision.
-
Congress passes RLUIPA
LegislationLawmakers unanimously enact the Religious Land Use and Institutionalized Persons Act, protecting the religious practice of prisoners. It rests on Congress's power to attach conditions to federal funding.
Historical Context
2 moments from history that rhyme with this story — and how they unfolded.
January 2015
Holt v. Hobbs (2015)
Gregory Holt, a Muslim inmate in Arkansas, sued under RLUIPA for the right to grow a half-inch beard. The Supreme Court ruled unanimously in his favor, finding the prison's no-beard policy violated the law.
Then
Holt won the right to keep his beard, and prisons nationwide reviewed grooming rules.
Now
The case confirmed RLUIPA's strength when inmates seek court orders changing prison policy.
Why this matters now
Holt got relief because he was still incarcerated and wanted a policy changed. Landor was already free, so only money could help him. The ruling shows where RLUIPA's protection ends.
December 2020
Tanzin v. Tanvir (2020)
Three Muslim men sued FBI agents personally for damages after being placed on the No Fly List for refusing to act as informants. The Supreme Court ruled unanimously that the Religious Freedom Restoration Act allows money damages against federal officials sued in their individual capacity.
Then
The men could pursue damages against the agents.
Now
It established that 'appropriate relief' under a sister religious-liberty law includes personal-capacity damages.
Why this matters now
Landor argued his case was the same. The Court disagreed, drawing a sharp line: RFRA rests on Congress's general power, while RLUIPA rests on the spending power, which it said cannot bind individuals.