WASHINGTON — The U.S. Supreme Court grappled Monday with a case involving a former Louisiana inmate whose dreadlocks were forcibly cut by prison guards, an act that allegedly violated his Rastafari religious beliefs. Damon Landor, who served a brief prison term in 2020, is seeking the right to sue for monetary damages under a federal law aimed at protecting inmates' religious freedoms.
The justices heard arguments in the case, known as Landor v. Louisiana Department of Corrections, 23-1197, which centers on whether the Religious Land Use and Institutionalized Persons Act allows individuals like Landor to hold prison officials financially accountable. While no one disputes the troubling nature of the incident, Louisiana argues that the law does not permit such lawsuits for damages, a position that has been upheld by lower courts.
Landor entered the Louisiana prison system in 2020 for a five-month sentence, carrying with him a copy of a federal appeals court ruling from another inmate's case that affirmed the religious significance of dreadlocks for Rastafarians. According to court records, officials at his first two facilities respected his beliefs and left his hair untouched. But the situation escalated when he was transferred to the Raymond Laborde Correctional Center in Cottonport, Louisiana, about 80 miles northwest of Baton Rouge, for the final three weeks of his term.
At the facility, a prison guard reportedly took Landor's copy of the court ruling and discarded it in the trash. The warden then ordered guards to cut his dreadlocks, which Landor had been growing for nearly two decades as part of his faith. Court documents describe how two guards restrained him while a third shaved his head to the scalp.
After his release, Landor filed a lawsuit seeking damages, but lower courts dismissed the case. The 5th U.S. Circuit Court of Appeals expressed regret over Landor's treatment but ruled that the federal law does not allow for financial liability against prison officials in such instances.
During Monday's Supreme Court arguments, which lasted two hours, the court's three liberal justices appeared supportive of Landor's position. However, the six conservative justices showed mixed reactions, with Justice Amy Coney Barrett acknowledging the severity of the case while noting the consistent rulings against similar claims in lower courts.
“Look, the facts of this case are egregious,” Justice Amy Coney Barrett said.
Barrett also expressed concern that every lower court to consider the issue had ruled against plaintiffs like Landor. The justices may draw guidance from a 2020 decision allowing Muslim men to sue over their placement on the FBI's no-fly list under the related Religious Freedom Restoration Act. In that case, the Justice Department opposed the plaintiffs during the Trump administration, but it now sides with Landor in this dispute.
Louisiana has since amended its prison grooming policy, stating in court filings that the changes ensure “nothing like petitioner’s alleged experience can occur” in the future. The state maintains that while the incident was regrettable, the law in question was not intended to provide a pathway for monetary damages against individual officials.
The case highlights broader tensions between prison regulations and religious freedoms, particularly for adherents of less mainstream faiths. Rastafari, which originated in 1930s Jamaica as a response to white colonial oppression among Black communities, incorporates Old Testament teachings and a longing for repatriation to Africa. Dreadlocks hold deep spiritual significance in the faith, symbolizing a covenant with God and resistance to societal norms.
The religion gained global prominence in the 1970s through Jamaican reggae icons like Bob Marley and Peter Tosh, who were prominent Rastafarians. Their music spread messages of empowerment, spirituality, and social justice, bringing attention to the faith's practices, including the wearing of dreadlocks as a religious observance.
Landor's experience is not isolated; similar cases have arisen in prisons across the U.S., where grooming policies often clash with religious accommodations. In the appeals court ruling Landor carried, another inmate successfully challenged dreadlock-cutting under the same federal law, but that decision focused on injunctive relief rather than damages.
Advocates for religious freedoms argue that allowing damages in such cases would deter future violations and provide meaningful recourse for inmates. The Justice Department, in its brief supporting Landor, emphasized that the law's protections should extend to financial remedies to fully safeguard religious exercise in institutional settings.
On the other side, Louisiana officials contend that expanding the law to include damages could open the floodgates to litigation, straining state resources and complicating prison administration. They point to the uniform lower court rulings as evidence that Congress did not intend for the statute to authorize such claims.
A decision in the case is expected by spring, potentially setting a precedent for how religious rights are enforced in prisons nationwide. If the court rules in Landor's favor, it could empower other inmates to seek compensation for similar violations, reshaping the landscape of prisoner litigation.
The outcome may also influence interpretations of related federal statutes, underscoring the Supreme Court's role in balancing individual rights against institutional interests. As the justices deliberate, Landor's story serves as a stark reminder of the challenges faced by religious minorities in correctional facilities, where personal beliefs can collide with rigid rules.