Supreme Court bars damages suits against prison officials under religious-rights law

Overview

Updated Jun 23

Three 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.

Voices

Curated perspectives — historical figures and your fellow readers.

Ever wondered what historical figures would say about today's headlines?

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 · 3 months ago

Tap a bar to jump to that date

June 2026
Court bars personal-capacity damages
Latest Ruling

The 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.
June 23rd, 2026
November 2025
Supreme Court hears argument
Legal

Justices question whether Congress can impose personal liability on officials through a spending-power law. The Court appears skeptical of Landor's position.
November 10th, 2025
August 2023
Fifth Circuit rejects Landor's damages claim
Legal

The 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.
August 18th, 2023
December 2020
Court allows damages under sister law
Legal

In 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.
December 10th, 2020
July 2020
Guards shave Landor's head
Incident

Weeks from release, Landor is handcuffed to a chair and shaved at Raymond Laborde Correctional Center. A guard throws his court ruling in the trash.
July 1st, 2020
July 2017
Appeals court protects Rastafarian hair
Legal

The Fifth Circuit rules in a Louisiana case that shaving Rastafarian inmates' hair generally violates RLUIPA. Landor later hands guards a copy of this decision.
July 1st, 2017
September 2000
Congress passes RLUIPA
Legislation

Lawmakers 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.
September 22nd, 2000

Scenarios

Congress amends RLUIPA to allow damages

Unlikely Resolves by End of 2027

Discussed by: Justice Gorsuch's majority opinion; Constitutional Accountability Center

The majority noted Congress could rewrite the law to permit personal-capacity damages. A bill restoring that remedy would require sponsors in both chambers and a path through a divided Congress. Religious-liberty and civil-rights groups across the spectrum have backed Landor, which could give such a fix unusual bipartisan appeal.

Ruling stands as the final word, no fix

Likely Resolves by End of 2027

Discussed by: SCOTUSblog; CBS News

With Congress gridlocked, the decision simply holds. Prisoners can still seek court orders to change prison policy, but those become moot once an inmate is released. For people like Landor, already free, no remedy remains. This is the default path if lawmakers take no action.

States pass their own damages remedies

Possible Resolves by End of 2027

Discussed by: Religious-liberty advocates cited in PBS and CNN coverage

States can write their own laws letting inmates sue prison staff for violating religious practice. Advocates may push such bills in legislatures, especially in states with active religious-freedom coalitions. At least one state would need to enact a measure creating a personal-capacity damages remedy for prison religious-rights violations.

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.