Supreme Court Rules Rastafarian Prisoner Cannot Sue Guards Over Forced Head Shaving

The Supreme Court ruled 6-3 that Rastafarian prisoner Damon Landor cannot sue individual guards for damages after they forcibly shaved his knee-length dreadlocks. The majority opinion, based on the Religious Land Use and Institutionalized Persons Act (RLUIPA), treated the law as a contract binding only the state, not its employees. The decision has potential implications for other federal laws, such as EMTALA, which protects emergency abortion access.

Landor forced head shaving incident

• ▪Damon Landor is a Rastafarian whose religion requires him to grow his hair, which he had done for over 20 years into knee-length dreadlocks
• ▪In 2020, while serving a five-month sentence for drug possession, Landor was transferred to the Raymond Laborde Correctional Center in Louisiana
• ▪Before the incident, Landor presented guards with a copy of a 2017 5th Circuit Court of Appeals ruling that found Louisiana's hair-cutting policy violated federal law for Rastafarians
• ▪A guard threw the copy of the court ruling in the trash before Damon Landor's head was shaved
• ▪At the Louisiana facility, Damon Landor was handcuffed to a chair while guards forcibly shaved his head

Supreme Court ruling details

• ▪Justice Ketanji Brown Jackson wrote a dissenting opinion, joined by Justices Sonia Sotomayor and Elena Kagan
• ▪On June 23, 2026, the U.S. Supreme Court ruled 6-3 that Damon Landor cannot sue individual prison officials for monetary damages
• ▪Following the incident, Louisiana officials said the state has amended its grooming policy to prevent a recurrence
• ▪The ruling was authored by Justice Neil Gorsuch and supported by the court's conservative majority

RLUIPA legal interpretation

• ▪In her dissent, Justice Jackson argued the majority's contract analogy "magically transforms a federal statute into an invitation to be accepted or declined."
• ▪The majority opinion reasoned that RLUIPA, enacted under the Constitution's Spending Clause, functions like a contract
• ▪The lawsuit was filed under the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), which protects prisoners' religious rights
• ▪The Court held that RLUIPA's conditions only bind the entity receiving federal funds, such as the state, not individual employees who did not personally agree to its terms

EMTALA abortion implications

• ▪The legal reasoning in the Landor decision may undermine other federal laws based on the Spending Clause, such as the Emergency Medical Treatment and Labor Act (EMTALA)
• ▪EMTALA requires hospitals receiving Medicare funds to provide stabilizing care, including emergency abortions, which can conflict with state abortion bans
• ▪The Landor ruling's logic suggests EMTALA cannot override state laws because the state is not a party to the "contract" between hospitals and the federal government