The United States Supreme Court ruled on Tuesday that Damon Landor, a Rastafarian former inmate whose knee-length dreadlocks were forcibly shaved by Louisiana prison guards, cannot seek monetary damages from the officials who violated his religious rights. The 6-3 decision, authored by Justice Neil Gorsuch, determined that the Religious Land Use and Institutionalized Persons Act (RLUIPA) of 2000 does not authorise lawsuits against state employees in their personal capacities, even when a violation is undisputed.

According to the majority opinion, Congress enacted RLUIPA under its spending power, which allows it to attach conditions to federal funds received by states. Because individual prison employees are not parties to that financial agreement, the Court held, they cannot be directly liable for damages. “Under the Spending Clause, Congress lacks regulatory authority to impose liability on them directly and must depend instead on consent,” Gorsuch wrote. In a dissent joined by the court’s three liberal justices, Justice Ketanji Brown Jackson argued that the ruling “reduces some of Congress’s greatest legislative achievements” to mere contractual dealings and warned that prisoners like Landor “will often be left remediless.” Louisiana’s attorney general acknowledged that the guards’ conduct was “antithetical to religious freedom” and said the state has since amended its prison grooming policy, but maintained that federal law does not permit individual-capacity damages suits.

The decision marks a departure from a series of recent Supreme Court rulings that have expansively interpreted religious liberty protections, often in favour of Christian plaintiffs. Legal observers in Washington note that the ruling’s logic, rooted in the Spending Clause, could affect other federal statutes that condition state funding on compliance with civil rights, healthcare, or environmental standards. The Trump administration had supported Landor’s appeal, arguing that accountability for religious burdens was essential. Civil liberties groups, including the American Civil Liberties Union and Americans United for Separation of Church and State, denounced the outcome, saying it erodes protections for incarcerated people and leaves religious minorities particularly vulnerable.

Landor, who had grown his hair for nearly two decades as an expression of his Rastafarian faith, said he was “disappointed but not defeated” and would continue pursuing accountability. The ruling resolves a long-standing division among lower federal courts, with at least ten appellate circuits having previously concluded that RLUIPA does not permit individual damages claims. The decision does not foreclose suits against state prison systems themselves, but it sharply limits the remedies available to inmates whose religious rights are violated by individual officers. No further legislative or judicial action is immediately expected, though the broader implications for Spending Clause legislation are likely to be tested in future litigation.