Overview
- After oral arguments, the Court’s conservative majority signaled skepticism that the Religious Land Use and Institutionalized Persons Act permits personal-capacity money damages, as the three liberal justices appeared more receptive.
- The case stems from a 2020 incident in which Louisiana prison guards discarded a court ruling Landor presented, handcuffed him to a chair, restrained him and shaved his knee-length dreadlocks in violation of his Rastafari beliefs.
- Landor urges the Court to read RLUIPA like its sister statute RFRA and extend the Court’s 2020 Tanzin v. Tanvir damages ruling, while several justices focused on Spending Clause limits and the need for a clear statement to hold non-funding recipients personally liable.
- Lower courts have uniformly held that RLUIPA does not allow damages against individual officials, and the U.S. Department of Justice supported Landor’s position alongside a cross-ideological array of amici.
- Louisiana acknowledged the conduct was wrong and revised its prison grooming policy, and a decision in Landor v. Louisiana Department of Corrections is expected by spring or summer 2026.