Landor v. Louisiana Dept of Corrections and Public Safety, Docket No. 23-1197

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A Louisiana inmate's head was forcibly shaved despite his Rastafarian faith requiring him to never cut his hair. When he tried to sue the prison officers responsible, the Supreme Court blocked his case. The decision means prisoners who suffer religious freedom violations in prison may have almost no way to get money damages, even when officials clearly violated federal law.

What Happened to Damon Landor

Damon Landor is a Rastafarian whose faith requires him to never cut his hair, a practice he had maintained for two decades. Near the end of his prison sentence in Louisiana in 2020, he was transferred to a new facility. Knowing there might be trouble, he brought a printed copy of a court ruling that said prisons generally cannot force Rastafarians to cut their hair. The intake officers threw his papers in the trash, handcuffed him to a chair, held him down, and shaved his head.

Landor sued the Louisiana Department of Corrections and several individual officers under a federal law called the Religious Land Use and Institutionalized Persons Act, or RLUIPA, seeking money damages. The Fifth Circuit Court of Appeals ruled that RLUIPA does not allow lawsuits against officers personally. The Supreme Court agreed, six to three.

Why the Court Sided With the Officers

The majority, led by Justice Gorsuch, decided the case on constitutional grounds. He reasoned Congress can attach conditions to federal funding and cut off that funding if those conditions are not met. But Congress cannot directly regulate people's behavior through the spending power unless those people voluntarily and knowingly agreed to be subject to those rules.

The Louisiana Department of Corrections accepted federal money and therefore agreed to follow RLUIPA's rules. But the individual officers never made any such agreement. Without that consent, the Court said, Landor's case against them cannot proceed, just as you cannot sue someone for breaking a contract they never signed.

The majority worried that allowing lawsuits against individual officers would give Congress essentially unlimited power. If simply receiving a paycheck from a federally funded employer counted as consent, then virtually every American who works for any organization that touches federal money could be directly regulated by Congress. The Court offered vivid examples of where that logic could lead, including coaches forced to allow transgender athletes to compete or doctors barred from administering vaccines, all under threat of personal lawsuits.

The Court acknowledged that Congress can criminalize bribery of officials at federally funded organizations without their personal consent. But the majority distinguished that as protecting federal dollars from being stolen. RLUIPA's cause of action, by contrast, advances a policy goal around religious liberty rather than protecting the integrity of federal funds.

What the Dissenters Said

Justice Jackson, joined by Justices Sotomayor and Kagan, argued the majority got it wrong on every level. The Supreme Court had already ruled unanimously that a nearly identical federal religious freedom law called RFRA allows damages against federal officials personally. RLUIPA should be read the same way, Jackson argued.

On the constitutional question, Jackson said the majority invented a new requirement that appears nowhere in the Court's prior spending power cases. She pointed to earlier decisions that upheld federal regulation of state employees and even private individuals who were not direct recipients of federal money.

Jackson also warned that the decision leaves prisoners who suffer religious liberty violations with almost no practical remedy. An earlier Supreme Court ruling already blocked money damages against states under RLUIPA. Now individual officers are protected too. That leaves only injunctive relief, meaning a court order to stop the violation, which is often rendered meaningless when a prisoner is transferred to a different facility before the case is resolved.

Regulating Conduct Through Federal Funding

Is a spending power law more like a law or more like a contract? The majority treats spending power laws as fundamentally consensual. The Court draws a sharp line between organizations that accept federal money and the individuals who work for them.

The practical gap left by this decision is significant. Prisoners who suffer religious freedom violations may have almost no way to get money damages, even when officials clearly violated federal law. The majority noted that Congress could restructure RLUIPA to require individual officers to sign separate agreements, or could condition funding on states passing their own damages laws. Whether either of those alternatives is realistic in practice remains to be seen.

The Supreme Court has made it much harder to hold individual government employees personally accountable for violating federal civil rights laws, even when those laws are designed to protect fundamental freedoms like religious practice. The decision reflects a deep disagreement about how much power Congress has to regulate conduct through federal funding.