389 events on record Subscribe June 25, 2026
Standing Record home The Standing Record A non-partisan record of US democratic norms —
and the events that erode them.

Supreme Court ruled 6-3 prisoners cannot sue individual guards for money damages under RLUIPA, eliminating key religious-freedom remedy

The U.S. Supreme Court ruled 6-3 on June 23, 2026 that prisoners cannot sue individual prison guards for money damages under the Religious Land Use and Institutionalized Persons Act (RLUIPA), leaving only injunctive relief as a remedy for religious freedom violations by prison staff. The case arose from Damon Landor, a Rastafarian man whose dreadlocks were forcibly cut by Louisiana prison guards in 2020. The conservative majority held that individual guards did not consent to personal liability under RLUIPA, while the dissent warned the ruling leaves prisoners with "little reason to expect guards to abide by legal protections."

Jurisdiction
federal
Location
Washington, D.C.

Abuses documented

Actors

On June 23, 2026, the U.S. Supreme Court ruled 6-3 that Damon Landor, a Rastafarian man, could not sue the individual Louisiana prison guards who forcibly shaved his dreadlocks in 2020 for money damages under the Religious Land Use and Institutionalized Persons Act (RLUIPA). Landor had entered the Raymond Laborde Correctional Center with a copy of a 2017 court ruling protecting prisoners' religious hair; a guard discarded the document and the warden ordered his hair cut. After serving five months, Landor brought a lawsuit seeking financial compensation from the individual officers. The Supreme Court's six-justice conservative majority held that RLUIPA does not waive individual state employees' immunity from personal liability for money damages, leaving only injunctive relief — an order to stop — as the available remedy.

RLUIPA was enacted by Congress in 2000 specifically to address the religious freedom of incarcerated people, who have no ability to seek services elsewhere and depend entirely on institutional accommodation. The statute was crafted after the Supreme Court had previously struck down a broader religious freedom law as applied to state governments, and Congress used its Spending Clause authority to impose RLUIPA on states accepting federal funds. The ruling's practical effect is to remove the primary financial deterrent against individual guards who violate prisoners' religious rights: an injunction to stop a completed violation offers no redress for what already occurred, and guards no longer face personal monetary exposure for their conduct.

The dissent, written by a liberal justice, warned that the ruling leaves prisoners with "little reason to expect guards to abide by legal protections for prisoners, absent any consequences for their actions." The 6-3 split followed strict ideological lines. Landor's case was notable for the clarity of the underlying violation — he arrived with documented proof of his legal right to maintain his dreadlocks, yet guards discarded the documentation and cut his hair regardless. The case name is Landor v. Louisiana Department of Public Safety and Corrections.

Why we recorded this

RLUIPA — the Religious Land Use and Institutionalized Persons Act — was enacted by Congress in 2000 specifically to protect the religious freedom of people in prisons, where practitioners cannot seek services elsewhere. By ruling that prisoners may not sue individual guards for money damages, the Court removes the primary financial deterrent against staff who violate those rights.

Sources

  1. US Supreme Court says Rastafarian man shaved by prison guards can't sue — Al Jazeera primary accessed June 24, 2026
  2. Supreme Court rules that prison guards can't be sued for shaving Rastafarian's head — NPR primary accessed June 24, 2026
  3. Court rules former Louisiana inmate cannot sue prison officials in religious dispute over long hair — SCOTUSblog secondary accessed June 24, 2026

See also