Supreme Court to Consider If Prisoners May Sue Officials Over Religious Rights

A federal appeals court previously held a former Louisiana inmate may not use a federal law to sue officials over alleged violations of his religious rights.

The U.S. Supreme Court in Washington on May 19, 2025. Madalina Vasiliu/The Epoch Times

The Supreme Court has agreed to consider whether prisoners who claim their religious rights have been violated may sue state officials personally for monetary damages.

The court’s new ruling on June 23 took the form of an unsigned order in Landor v. Louisiana Department of Corrections and Public Safety. No justices dissented. The court did not explain its decision.

The justices will look at whether damages are allowed under the federal Religious Land Use and Institutionalized Persons Act (RLUIP), which forbids state officials from restricting or infringing religious rights.

In Tanzin v. Tanvir (2020), the Supreme Court ruled unanimously that Muslims placed on the so-called no-fly list after refusing to act as informants for the FBI may sue individual government officials personally for damages under the RLUIP’s similarly worded companion legislation, the Religious Freedom Restoration Act (RFRA).

The U.S. Department of Justice told the Supreme Court in a May 7 brief that the issue in this case is whether “appropriate relief” under RLUIPA may encompass monetary damages in lawsuits filed against government officials in their capacities as individuals.

Tanzin v. Tanvir held that “appropriate relief ” under RFRA may include monetary damages against government officials in their individual capacities. “No sound basis exists to reach a different conclusion with respect to RLUIPA,” the brief said.

The petitioner is Damon Landor, a Rastafarian, who, for religious reasons, opposes cutting his hair. Prison officials in Louisiana forcibly shaved Landor’s head, despite him previously receiving religious accommodations while incarcerated elsewhere. Court papers do not indicate why he was incarcerated.

When he began serving a five-month term at a prison in Louisiana, he had kept his promise not to cut the hair on his head for nearly 20 years. His hair at the time nearly reached his knees, according to his petition filed on May 3, 2024.

He was housed for four months in a facility that “respected Landor’s vow and allowed him to either wear his hair long or to keep it under a ‘rastacap.’”

With weeks remaining in his sentence, he was transferred to the Raymond Laborde Correctional Center at which the warden “demanded Landor hand over documentation from his sentencing judge that corroborated his religious beliefs.” Landor then offered to have his attorney supply those materials but the warden allegedly said it was “too late for that.” Landor was physically restrained while guards shaved him, the petition said.

Landor sued the warden, guards, and James LeBlanc, the state secretary of the Department of Corrections and Public Safety, not in their capacities as officials, but as individuals, for damages under the RLUIP. The federal district court approved a motion to dismiss the lawsuit because the U.S. Court of Appeals for the Fifth Circuit precedent does not allow claims for damages against individual state officials, the petition said.

The Fifth Circuit affirmed, holding that prior circuit court precedent meant that “under RLUIPA, [Landor] cannot seek money damages from officials in their individual capacities.” The court held that Tanzin v. Tanvir had not overruled circuit precedent and that the texts of RFRA and RLUIPA were “almost the same.”

Louisiana said in an Aug. 7, 2024, brief that the Supreme Court should not take up the appeal because circuit court precedents are not on Landor’s side.

Landor “faces a wall of precedent from coast to coast foreclosing his view that RLUIPA permits money damages against state officials sued in their individual capacities,” the brief said.

The case is expected to be heard in the Supreme Court’s new term, which begins in October.