Supreme Court Says Rastafarian Can’t Sue Prison Officials Who Shaved His Dreadlocks

The court seemed skeptical of Damon Landor’s case during oral argument in November.

The Supreme Court in Washington on May 21, 2026. Madalina Kilroy/The Epoch Times

The Supreme Court said on June 23 that a Rastafarian could not sue prison officials in their individual capacities after the officials shaved his dreadlocks.

In a 6–3 decision, the justices said that the officials did not knowingly consent to liability under a federal law protecting prisoners’ religious liberty. Justice Ketanji Brown Jackson penned a dissenting opinion, joined by Justices Elena Kagan and Sonia Sotomayor.

Justice Neil Gorsuch wrote the majority opinion in the case, known as Landor v. Louisiana. He said that the law in question—the Religious Land Use and Institutionalized Persons Act—was unique because it was passed under the Constitution’s spending clause.

“Under the Spending Clause, Congress lacks regulatory authority to impose liability on them directly and must depend instead on consent,” he said. “And because [the officers] never agreed to answer suits like this one, Mr. Landor’s case cannot proceed against them any more than a breach of contract action might proceed against a defendant who never formed a contract.”

Justice Ketanji Brown Jackson penned a dissenting opinion, joined by Justices Elena Kagan and Sonia Sotomayor, in which she accused the majority of “a sleight of hand.”

“Today’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,” she said. “No matter that laws, as opposed to contracts, don’t ordinarily work this way.”

The case focused on wording in both the Religious Land Use and Institutionalized Persons Act and the Religious Freedom Restoration Act—both federal laws aimed at protecting the right to religious liberty.

In a 2002 case known as Tanzin v. Tanvir, the Supreme Court ruled on the Religious Freedom Restoration Act. It said that people could sue public officials in their individual capacities for violations of religious liberty.

Landor sought to apply that same principle to the Religious Land Use and Institutionalized Persons Act, which Congress passed to protect against religious violations for individuals confined in prisons and other state-run institutions.

Landor told the Supreme Court that a “Nazirite vow” compelled him to keep his dreadlocks.

The U.S. Court of Appeals for the Fifth Circuit said that while Landor “clearly suffered a grave legal wrong,” he couldn’t sue the officials for money damages in their individual capacities.

Part of their reasoning was based on a provision of the Constitution known as the spending clause.

That clause gives Congress the power to collect taxes and other forms of revenue “to pay the debts and provide for the common defence and general welfare of the United States.”

According to the Supreme Court, the Religious Land Use and Institutionalized Persons Act was enacted under that authority.

In the Fifth Circuit’s view, the Religious Land Use and Institutionalized Persons Act was like a contract, with liability assigned to the parties involved.

That liability, it said, should apply only to actual parties to the contract, such as a state government that receives federal funding. Because guards in their individual capacity are not parties to a particular contract, they cannot be held liable in that capacity.