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
- Argued – pending decision
- Argued date: November 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.
As the 2024 resolution “On Defending Religious Liberty” states, “the state has no right to impose penalties for religious opinions of any kind,” along with numerous Southern Baptist resolutions throughout our history which reject government restriction of religious opinion and limit government infringement of religious expression;”
Post-oral arguments
A majority of the justices seemed skeptical about RLUIPA’s language providing a right to pursue individual capacity damages when rights are violated. While RFRA grants such rights, RLUIPA is grounded in Congress’s spending power, meaning states and state employees must be given clear notice and accept that they will be liable for damages if they violate RLUIPA. Justice Kavanaugh said he did not feel the language for appropriate relief in RLUIPA was “as clear as it could be.” While the justices may not rule in Landor’s favor, Congress could further amend the statute to ensure RLUIPA is enforceable and victims can receive proper remedy.
