The Supreme Court ruled 6-3 on Tuesday that a Rastafari prisoner whose dreadlocks were forcibly shaved by Louisiana prison guards cannot sue those guards for monetary damages, even though every party in the case, and every justice on the bench, agreed the guards' conduct violated federal religious-liberty law.

The decision in the case of Damon Landor, docket No. 23-1197, split along ideological lines. Justice Neil Gorsuch wrote for the six-justice conservative majority. Justice Ketanji Brown Jackson dissented, joined by Justices Sonia Sotomayor and Elena Kagan.

The ruling turns on a narrow but consequential legal distinction: because the Religious Land Use and Institutionalized Persons Act was enacted under Congress's spending power, the majority held, individual state employees who never personally agreed to the statute's terms cannot be forced to pay damages under it. The practical result is that Landor, who endured a clear violation of his religious rights while in state custody, walks away with nothing.

What happened to Damon Landor

Landor, a Rastafari man, was serving a five-month drug sentence at a Louisiana prison. He was weeks away from completing that sentence when guards decided to cut his hair.

Before they did, Landor handed them a federal appeals court ruling, from the 5th U.S. Circuit Court of Appeals, that said shaving Rastafari inmates' dreadlocks violates RLUIPA. The guards threw the ruling in the trash. They handcuffed Landor to a chair and shaved him bald.

As the Washington Examiner reported, Landor had spent nearly two decades growing his dreadlocks "nearly to his knees" in accordance with Rastafarian tradition. His court filing stated that prison officials "stripped him of decades of religious practice at the heart of his identity."

Nobody disputes the violation. All sides in the litigation condemned the guards' treatment of Landor. The only question before the Supreme Court was whether RLUIPA allows a prisoner to recover damages from the individual state employees who carried out the violation.

The majority's reasoning

Justice Gorsuch grounded the decision in the spending-power framework. RLUIPA was enacted as a condition on federal funding to state institutions. Under longstanding precedent, Congress must make the terms of such conditions crystal clear before states, or their employees, can be held liable.

Gorsuch wrote that Landor "does not allege that any of those individuals has entered any agreement with the federal government, let alone that any of them has voluntarily and knowingly consented to answer private suits under RLUIPA."

"Congress must clearly and unambiguously alert a grant recipient to any condition on federal funds."

In other words, the majority treated RLUIPA like a contract between the federal government and state institutions. The guards themselves never signed that contract. So they cannot be personally liable for breaking its terms.

The Court has been active this term on several fronts, including an 8-1 ruling preserving FCC telecom enforcement power that drew broad agreement across the ideological spectrum.

The dissent pushes back

Justice Jackson's dissent did not hold back. She accused the majority of warping a federal statute into something it was never meant to be, a voluntary arrangement rather than binding law.

"Today's decision magically transforms a federal statute into an invitation to be accepted or declined, deemed binding only if each particular defendant has explicitly agreed to be penalized."

Jackson added pointedly: "No matter that laws, as opposed to contracts, don't ordinarily work this way."

The three liberal justices characterized the majority's position as peculiar, arguing that the ruling effectively immunizes individual state actors from accountability for conduct that everyone acknowledges was unlawful. Under the majority's logic, a prison guard can violate a federal religious-liberty statute with impunity so long as the guard personally never agreed to be bound by it.

An unusual coalition backed Landor

What makes this case remarkable is the breadth of support Landor attracted, and how little it mattered.

The Trump administration argued the case alongside Landor's attorney, siding with the inmate against the state. Republican Sens. Ted Cruz of Texas and Ted Budd of North Carolina filed amicus briefs supporting Landor's right to seek damages. The Becket Fund for Religious Liberty, a conservative legal organization, also filed a brief on his behalf. Various unnamed religious groups joined as well.

As the Washington Times reported during oral arguments last November, Landor's attorney Zachary Tripp told the Court that his client "was at Respondents' mercy in federally funded custody when he handed them a copy of controlling precedent holding that [the law] protected his right to keep his hair long. They threw it away, handcuffed him to a chair, and shaved him bald."

Louisiana Solicitor General J. Benjamin Aguinaga countered that "RLUIPA does not clearly and unambiguously create an individual capacity cause of action for damages," arguing the remedy Landor sought belonged in state court, not before the Supreme Court.

Louisiana Attorney General Liz Murrill, a Republican, opposed Landor's damages claim on legal grounds while condemning the guards' behavior. Her office's court filing argued that "Congress did not unambiguously permit suits against officials in their personal capacities, much less suits for damages."

The Court has also been weighing other significant cases this term, including whether ICE can hold criminal immigrants without bond hearings, another dispute over the scope of federal authority and individual rights within government custody.

The RFRA distinction

The ruling's logic rests on a comparison the majority drew between two sister statutes. RLUIPA, the law at issue here, was enacted under Congress's spending power. The Religious Freedom Restoration Act of 1993, by contrast, was not.

In 2020, the Supreme Court ruled unanimously that RFRA does permit damage suits. That case involved Muslim men placed on the No Fly List. Because RFRA was not enacted under the spending power, the consent-of-the-recipient framework did not apply.

The distinction matters enormously for prisoners. RLUIPA is the primary federal statute protecting inmates' religious exercise. If it cannot support damages claims against individual guards, the deterrent effect of the law shrinks considerably. Guards who violate prisoners' religious rights may face injunctive relief, a court order to stop, but not personal financial consequences.

That gap is precisely what the dissent highlighted. And it is precisely what made the case attractive to religious-liberty advocates across the political spectrum, from the Becket Fund to Republican senators to the Trump administration itself.

In another recent term development, the Court delivered an 8-1 ruling on Cuba property claims, showing that broad consensus is possible even in a polarized term.

What the ruling leaves unanswered

Several questions remain open. The Hill reported that the 5th Circuit had previously ruled Landor could not sue the guards individually, and the Supreme Court has now affirmed that conclusion. But the decision does not address whether Landor could pursue other remedies, through state tort law, for instance, or against the institution rather than the individual guards.

The specific guards who shaved Landor were never named in the litigation as reported. The exact date of the shaving incident was not stated. Whether Landor completed his sentence remains unclear.

What is clear is the result: a man whose religious rights were violated in a manner condemned by every party to the case has no federal damages remedy against the people who did it.

The Court has also declined to hear other cases this term that raised difficult questions about federal authority and individual accountability.

A hard case with no clean answer

Conservatives who care about religious liberty should sit with the discomfort this case produces. The majority opinion is not unreasonable on its own terms. Spending-power legislation does impose different constraints than other kinds of federal law. The principle that Congress must speak clearly before imposing liability on individuals who never consented to federal conditions has deep roots.

But the facts of this case test that principle to its limit. Prison guards handcuffed an inmate to a chair, threw a court order in the trash, and shaved off decades of religious practice. Every justice agreed it was wrong. The Trump administration said it was wrong. Republican senators said it was wrong. Conservative religious-liberty groups said it was wrong.

And the man it happened to gets nothing.

When a legal framework produces a result that every participant in the system condemns but no one can fix, the framework deserves a harder look, not from the bench, but from the body that wrote the statute in the first place. Congress enacted RLUIPA to protect religious exercise behind prison walls. If the law cannot hold accountable the individual actors who violate it, then Congress left the job half-finished.

Religious liberty means nothing if the people who trample it face no consequences. That principle does not belong to the left or the right. It belongs to the Constitution.