Landor v. Louisiana Department of Corrections and Public Safety is about whether individuals can seek monetary damages against government officials who violate their religious liberty rights under the Religious Land Use and Institutionalized Persons Act (RLUIPA).
Case Status
- Decided – loss for religious liberty protections
- 6-3 ruling
- Decision date: June 23, 2026
- Argued date: Nov. 10, 2025
ERLC Brief
Amicus brief joined by ERLC
What is this case about?
Damon Landor, a practicing Rastafarian, was imprisoned in Louisiana for five months as a part of a drug possession sentence. As a part of his Rastafarian faith, he did not cut his hair for 20 years to grow dreadlocks as a part of his religious expression. In accordance with federal appeals courts precedent, his first prison accommodated his hair. However, a few weeks before the end of his sentence, he was transferred to a new prison. While there, a guard and warden threw his court decision in the trash, handcuffed him to a chair, and forcibly shaved his head.
The abuse committed against him clearly violates the Religious Land Use and Institutionalized Persons Act (RLUIPA), a sister statute of the Religious Freedom Restoration Act (RFRA). RLUIPA prevents the state from substantially burdening the religious expression of inmates. Upon his release, Landor sued the officials for monetary damages, but the lower courts argued that was not appropriate relief under RLUIPA.
What is the question in the case?
Whether an individual may sue a government official in his individual capacity for damages for violations of the RLUIPA.
Why does it matter to Southern Baptists?
While this case centers on a Rastafarian man and his hair as religious expression, the question at the center of the case holds broad implications for religious liberty for Christians as well. For example, a similar case centering on a Christian inmate who had his Bible forcibly taken from him could be brought on the same grounds. Even more broadly, since RLUIPA and RFRA are sister statutes containing identical language for individual-capacity damages, it is important the language be interpreted identically. Any other interpretation risks watering down religious exercise protections under RLUIPA, unless Congress acts to amend the statute.
Religious liberty is a long-standing Baptist distinctive. Along with numerous Southern Baptist resolutions throughout our history which reject government restriction of religious opinion and limit government infringement of religious expression, the 2024 SBC resolution asserts “The state has no right to impose penalties for religious opinions of any kind.” Furthermore, the 2026 resolution ‘On the 250th Anniversary of the United States and the Baptist Contribution to Religious Liberty’‘On Defending Religious Liberty’ reminds us of “our historic Baptist commitment to religious liberty for all people, recognizing it as a God-given right grounded in the dignity of every human being made in the image of God.”
Supreme Court Ruling
In a 6-3 decision, the Supreme Court issued an opinion against Landor, ruling that the Religious Land Use and Institutionalized Persons Act (RLUIPA), a key religious liberty statute, does not allow individuals working on behalf of the government to be personally sued for monetary damages when they violate a prisoner’s religious liberty.
In the majority opinion, Justice Gorsuch, joined by Chief Justice Roberts, and Justices Thomas, Alito, Kavaugh, and Barrett, expressed that Landor cannot bring a lawsuit seeking damages from the prison officials that forcibly shaved his head in their personal capacity. The majority reasons that, although RFRA and RLUIPA use identical language, RLUIPA is grounded in Congress’s Spending Clause Power, whereas RFRA is not. As such, Justice Gorsuch writes, “Under the Spending Clause and our precedents, voluntary and knowing consent is key” on the part of the people who could be held personally liable for damages (Pg. 9).
The dissenting opinion was written by Justice Jackson and was joined by Justices Sotomayor and Kagan.
