Damon Landor, a devout Rastafarian who follows the religion's Nazarite Vow against cutting one's hair, cannot seek monetary damages under the Religious Land Use and Institutionalized Persons Act from 10 guards and the former warden of Raymond Laborde Correctional Center in Cottonport, Louisiana, for handcuffing him to a chair and shaving his head over his objections in 2020, the justices ruled in a 6-3 decision.
RLUIPA, which prohibits state and local governments that receive federal funding from regulating land and institutions in a way that discriminates based on religion, doesn't authorize lawsuits against government officials in their person capacities unless they "voluntarily and knowingly consented" to be held liable under the law, unlike its "twin" statute that prohibits religious discrimination on the federal level, Justice Neil Gorsuch wrote for the court.
"Under the spending clause, Congress lacks regulatory authority to impose liability on them directly and must depend instead on consent," he said. "And because they never agreed to answer suits like this one, Mr. Landor's case cannot proceed against them any more than a breach of contract might proceed against a defendant who never formed a contract."
Tuesday's ruling is distinct from the Supreme Court's 2020 decision in Tanzin v. Tanvir
, which determined the Religious Freedom Restoration Act — RLUIPA's federal sister statute — allows plaintiffs to pursue claims against federal officials in their individual capacities.Justices Sonia Sotomayor, Elena Kagan and Ketanji Brown Jackson dissented, with Justice Jackson writing for the trio that the majority's decision "magically transforms a federal statute into an invitation to be accepted or declined, deemed binding only if each particular defendant has explicitly agreed to be penalized."
"The majority's analysis is spellbindingly straightforward: spending clause statutes are contracts, and contracts bind only those who consent," she wrote. "But pulling this rabbit out of the hat requires misconstruing the spending clause and the necessary and proper clause, and ignoring decades of precedent affirming Congress's authority to use the power of the purse to govern."
"In the end," she adds, "the court reduces some of Congress's greatest legislative achievements — federal laws that secure civil rights, environmental stability, healthcare, and more — to nothing more than the wheelings-and-dealings of an especially wealthy private party."
Landor's lawsuit arises from his August 2020 transfer to the Raymond Laborde Correction Center just weeks before he was scheduled to finish a five-month prison sentence for drug possession charges.
According to court documents, when he arrived at the facility, Landor objected to the mandatory haircut, showing the prison guards a copy of a Fifth Circuit decision in favor of a fellow Rastafarian that had found the Louisiana Department of Corrections and Public Safety's prohibition on inmates having dreadlocks was unlawfully burdensome under RLUIPA.
But the guards proceeded with the haircut. They threw away Landor's copy of the Fifth Circuit opinion, handcuffed him to a chair and forcibly shaved his head.
After his release, Landor sued the prison guards and Raymond Laborde's then-warden, seeking monetary damages from each of them in their individual capacities. However, a Louisiana federal judge dismissed his case under Fifth Circuit precedent that bars individual capacity RLUIPA lawsuits for monetary damages.
A unanimous three-judge Fifth Circuit panel affirmed the ruling while "emphatically" condemning Landor's treatment. The panel held that Congress had enacted RLUIPA under its spending clause power, so only the recipient of federal funding — Louisiana in this case — can be held liable for violating the act.
Landor asked the Supreme Court to reverse the panel's decision in May 2024.
Landor is represented by Zachary D. Tripp, Joshua M. Wesneski, Rachael E. Jones, Laurel L. Zigerelli, Sarah M. Sternlieb, Natalie Howard and Tiffany Kim of Weil Gotshal & Manges LLP and Casey Denson.
The Louisiana Department of Corrections and Public Safety is represented by J. Benjamin Aguiñaga, Zachary Faircloth, Morgan Brungard, Kelsey L. Smith, Caitlin A. Huettemann and Elizabeth Brown of the Louisiana Department of Justice.
The case is Landor v. Louisiana Department of Corrections and Public Safety et al., case number 23-1197, in the Supreme Court of the United States.
--Editing by Alyssa Miller.
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