Supreme Court rules prisoners cannot sue officials for money damages under religious-freedom law
The Supreme Court ruled 6-3 in Landor v. Louisiana Department of Corrections that prisoners cannot recover money damages from individual officials under the Religious Land Use and Institutionalized Persons Act (RLUIPA). The case arose after Damon Landor, a devout Rastafarian, gave guards a copy of a 2017 appeals-court ruling protecting Rastafarian inmates’ hair; the guards threw it away, handcuffed him to a chair and shaved his head weeks before his release.
Writing for the majority, Justice Neil Gorsuch held that RLUIPA — enacted under Congress’s spending power, which conditions federal funding on compliance — does not clearly authorize damages claims against individual officials, and that such suits cannot proceed absent the officials’ consent to liability. Spending-power statutes, Gorsuch wrote, must “clearly and unambiguously” alert recipients to any condition on federal funds, a bar RLUIPA does not meet for personal-capacity damages.
In dissent, Justice Ketanji Brown Jackson warned that prisoners who suffer religious-freedom violations in state prisons “will often be left remediless,” because injunctive relief is moot once an inmate is released or transferred. The practical effect is that even egregious violations like Landor’s may carry no financial consequence for the officials responsible, narrowing the law’s enforcement to forward-looking court orders.