Landor v. Louisiana, Department of Corrections
Case Overview
Damon Landor is a devout Rastafarian who kept his dreadlocks for 20 years as a religious obligation, and three weeks before he was released from a Louisiana prison, guards handcuffed him to a chair and shaved his head, despite documentation of prior religious accommodations and a Fifth Circuit ruling specifically protecting Rastafarian inmates. The question before the Supreme Court is whether RLUIPA, the federal law protecting religious practice in prisons, gives inmates the right to sue government officials for money damages when that protection is violated. Landor has since been released, which means an injunction does him no good, and the damages question is the whole case. Argued November 2025, still pending as of May 2026, with the court appearing skeptical at oral argument.
Decision
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Opinion of the Court
The Facts
Landor, a prisoner in Louisiana, brought claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA) alleging that the Department of Corrections violated his right to religious exercise. He sought money damages against state officials. Lower courts dismissed the damages claim, finding that RLUIPA does not authorize money damages suits against states or state officials in their individual capacities.
The Issue
Whether RLUIPA authorizes suits for money damages against state officials in their individual capacities Whether Congress validly abrogated sovereign immunity for RLUIPA damages claims against states
The Rules
protects institutionalized persons' religious exercise; authorizes 'appropriate relief against a government'
RFRA authorizes individual-capacity damages suits; RLUIPA shares parallel statutory language
bars suits against states unless Congress validly abrogates or state consents
The Application
Landor argues RLUIPA's text authorizes 'appropriate relief against a government' and should include money damages against state officials in their individual capacities, consistent with Tanzin v. Tanvir (2020), which held the parallel Religious Freedom Restoration Act permits individual-capacity damages. RLUIPA and RFRA share the same relevant statutory language.
Louisiana argues RLUIPA's Spending Clause basis limits available remedies — states accepted RLUIPA's conditions on federal funding but did not consent to individual-capacity money damages. The Eleventh Amendment bars such suits, and RLUIPA's text does not clearly override sovereign immunity or create a private damages remedy against state officials.
Argued November 10, 2025 — the earliest argued case still pending this term. Tanzin v. Tanvir (2020) supports Landor's reading for RFRA; the question is whether RLUIPA's Spending Clause basis distinguishes it. The ruling will determine whether prisoners nationwide can seek money damages for religious liberty violations in state correctional facilities.
The Conclusion
The Court held 6-3 that RLUIPA, as a Spending Clause statute, cannot impose personal liability on individual state employees who never personally agreed to its terms as a condition of receiving federal funds. Damon Landor, a Rastafarian inmate whose head was forcibly shaved, cannot seek money damages directly from the officers under the religious freedom law.
No circuit court data for this case.
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