The U.S. Supreme Court ruled Tuesday that state prison officials cannot be held personally liable for monetary damages under the Religious Land Use and Institutionalized Persons Act, or RLUIPA, in a 6-3 decision that clarifies the scope of the federal religious liberty law.
The ruling came in the case of Landor v. Louisiana Department of Corrections and Public Safety.
Justice Neil Gorsuch wrote the majority opinion, joined by Chief Justice John Roberts and Justices Clarence Thomas, Samuel Alito, Brett Kavanaugh and Amy Coney Barrett.
The court upheld a lower court ruling dismissing claims against individual Louisiana prison officials brought by former inmate Damon Landor.
Landor, a Rastafarian, alleged prison officials violated his religious rights in 2020 by forcibly cutting his dreadlocks while he was incarcerated at Louisiana’s Raymond Laborde Correctional Center.
According to court filings, Landor said he informed prison officials that his dreadlocks were protected by his religious beliefs and presented a copy of a federal appeals court decision addressing Louisiana’s grooming policy.
He alleged officials discarded the document, restrained him and shaved his head before his release.
Landor sued the Louisiana Department of Corrections and Public Safety, Secretary James LeBlanc, the correctional center and Warden Marcus Myers under RLUIPA and other legal claims.
He sought monetary damages from prison officials in their individual capacities.
The Supreme Court ruled that RLUIPA, which was enacted under Congress’ Spending Clause authority, does not authorize personal-capacity damages against state officials.
Writing for the majority, Gorsuch said Spending Clause legislation functions like a contract, requiring parties to knowingly and voluntarily accept its conditions.
The opinion concluded that individual state employees did not personally consent to liability under the statute.
The ruling leaves intact other legal remedies available under RLUIPA.
Prisoners may still seek court orders requiring changes to prison policies and may pursue claims against government entities in their official capacities.
The decision also does not affect separate constitutional claims that may be brought under federal civil rights law.
Justice Ketanji Brown Jackson dissented, joined by Justices Sonia Sotomayor and Elena Kagan.
Jackson argued the decision limits available remedies for inmates whose religious rights have been violated, per the Conservative Brief.
She wrote that similar language in the Religious Freedom Restoration Act has been interpreted to permit damages and said RLUIPA should receive the same reading.
The case centered on whether Congress intended to expose individual state employees to personal financial liability when it enacted the law in 2000.
The court concluded it did not.
Louisiana has since revised its prison grooming policies regarding religious accommodations.
Louisiana Attorney General Liz Murrill welcomed the ruling, saying it provides clarity on the scope of the statute while noting the state supports religious liberty protections.
The decision marks the latest Supreme Court ruling addressing the balance between federal statutory protections for religious exercise and the limits of congressional authority under the Spending Clause.
