Supreme Court Rules Louisiana Prisoner Cannot Sue Guards Who Forcibly Shaved His Dreadlocks

Picture this: You're days away from finishing your prison sentence. You've already done four months without incident. You practiced your faith carefully the whole time. Then, on transfer to one final facility, guards handcuff you to a chair and shave off nearly two decades of hair — hair you grew as a sacred religious vow — after throwing in the trash the very court order that protected your right to keep it.

That's exactly what happened to Damon Landor, a devout Rastafarian, in 2020. And this week, the Supreme Court said he has no legal recourse against the guards who did it.

Here's the situation: Landor had only three weeks left on his sentence when he was transferred to the Raymond Laborde Correctional Center in Louisiana. He had grown his dreadlocks for nearly 20 years as part of a religious practice called the Nazarite Vow — a commitment to never cut his hair. His previous two prisons had respected that. He wasn't taking any chances at the new one, so he carried a copy of a 2017 federal court ruling that specifically required Louisiana prisons to honor Rastafarian religious practices.

When he handed it to an intake guard, the guard threw it in the trash. The warden demanded paperwork from Landor's sentencing judge — something nobody could produce on the spot. So two guards carried Landor into another room, handcuffed him to a chair, and shaved his head.

After getting out, Landor sued the individual guards under a federal law called RLUIPA — short for the Religious Land Use and Institutionalized Persons Act — which was specifically designed by Congress to protect the religious rights of prisoners.

But here's where the legal twist comes in. The Supreme Court, in a 6-3 ruling along ideological lines, said that law doesn't actually let you sue individual guards for money. Justice Neil Gorsuch wrote the majority opinion, hinging the decision on something called the Spending Clause — basically the part of the Constitution that lets Congress give money to states with strings attached. The majority's reasoning: laws tied to federal funding work like contracts between the federal government and a state. The individual guards at the prison aren't the ones who signed that contract, and since they didn't personally agree to be held liable under the law, Landor can't sue them directly for damages.

In plain terms: yes, what happened was wrong. Even the court said so. Even Louisiana's own attorney general condemned it and said the state has since updated its grooming policies. But the court's majority said the law, as written, doesn't give Landor a path to hold those specific guards financially accountable.

The three liberal justices — led by Justice Ketanji Brown Jackson — dissented sharply. Jackson accused the majority of constructing a legal fiction, arguing that what protects prisoners here is a law, not a contract, and that the ruling effectively strips Congress of the power to enforce protections it deliberately created. Her warning: prison officials now have little incentive to follow federal religious rights law because there's no personal financial consequence if they don't.

Harvard law professor Noah Feldman called the implications wide-ranging, warning the logic could extend far beyond prisons — potentially allowing federal officials in other contexts to claim immunity from the laws they're supposed to follow.

Landor himself isn't done. 'I will continue pursuing accountability,' he said in a statement through his legal team. And his attorneys noted that Congress could step in and amend RLUIPA to make damages available — but that's a political fight, not a legal one, and it's far from certain.

Why does this matter to you personally? If you believe the government — at any level — should be held personally accountable when it violates your rights, this ruling chips away at that. It says Congress can write a law protecting your religious freedom, but if those protections are built on federal funding, the individual officials who break the rules may be shielded from personal consequences. That's a gap worth knowing about.