The Supreme Court ruled 6-3 that prison guards who forcibly shaved a man’s religiously grown dreadlocks cannot be personally sued for money — and the three liberal justices, not the conservatives, were the ones fighting hardest to let the lawsuit proceed.

Story Snapshot

• Justice Neil Gorsuch wrote the majority opinion, ruling that prison guards cannot be personally sued for money damages under the Religious Land Use and Institutionalized Persons Act (RLUIPA) unless they personally agreed to that liability.
• Justice Ketanji Brown Jackson led the dissent, joined by Justices Sotomayor and Kagan, arguing the ruling “magically transforms a federal statute into an invitation to be accepted or declined.”
• The case involved Damon Landor, a Rastafarian whose dreadlocks — grown for over 20 years as part of his faith — were forcibly shaved by Louisiana prison guards.
• The ruling turns on a key legal difference: RLUIPA was passed under Congress’s spending power, which means it binds states that accept federal money — not individual guards who never signed any agreement.

Guards Shaved a Man’s Sacred Dreadlocks — But Can’t Be Personally Sued

Damon Landor is a devout Rastafarian who had grown his dreadlocks for more than 20 years as part of a biblical Nazirite vow. While held in a Louisiana state prison, guards forcibly shaved his head. Landor sued the individual guards for money damages under the Religious Land Use and Institutionalized Persons Act (RLUIPA), a federal law that protects the religious rights of prisoners in facilities receiving federal funds. Both the district court and the Fifth Circuit Court of Appeals dismissed his individual-capacity claims.

The Supreme Court agreed with the lower courts and ruled against Landor 6-3 on June 24, 2026. Justice Gorsuch, writing for the majority, explained the core legal reason clearly: RLUIPA was passed under Congress’s spending power. That means it works like a contract — the state of Louisiana agreed to follow the law when it accepted federal money. But the individual guards, Le Blanc and Myers, never personally signed that agreement. They cannot be held personally liable for something they never consented to. ^[3]

Why the Spending Clause Makes All the Difference

This case hinges on a legal distinction that matters a great deal. When Congress passes a law using its spending power, it is essentially setting conditions on federal money. States agree to those conditions when they take the funds. But that agreement is between the federal government and the state — not between the federal government and every individual employee. Courts have consistently held that individual employees cannot be sued personally under spending-power laws unless they personally and knowingly agreed to face that liability. ^[3]

This is different from the Religious Freedom Restoration Act (RFRA), a similar law. RFRA was passed under a broader constitutional power — Section 5 of the Fourteenth Amendment — which gives Congress more authority to impose direct liability on individuals. The Supreme Court previously ruled in Tanzin v. Tanvir (2020) that RFRA does allow individual-capacity damages suits. Critics of the Landor ruling argue that RLUIPA uses nearly identical language and should be read the same way. But the majority said the different constitutional foundation changes everything. ^[1]

Jackson’s Dissent vs. Gorsuch’s Majority — Who Has the Better Argument?

Justice Jackson’s dissent was sharp. She argued that RLUIPA’s text plainly allows individual-capacity lawsuits and that the majority was treating a federal law like an optional contract. “Laws, as opposed to contracts, don’t ordinarily work this way,” she wrote. Justices Sotomayor and Kagan joined her. Notably, all three liberal justices sided with expanding the lawsuit — a reversal of the media narrative that framed this as conservatives blocking religious rights. ^[3]

Supreme Court Rejects Rastafarian Man’s Lawsuit Over Forced Shaving Of His Dreadlockshttps://t.co/zESYfGWJJz

— Blavity (@Blavity) June 24, 2026

Gorsuch’s majority opinion, however, rests on solid legal ground. The spending-power framework has long been understood as a conditional agreement between Congress and recipient states — not a direct command to every individual within those states. Ten federal appeals courts had already ruled the same way before this case reached the Supreme Court. ^[11] The Court’s ruling does not say Landor’s rights weren’t violated. It says the specific legal tool he used — suing guards personally under a spending-power statute — does not work without their consent. That is a principled reading of constitutional limits, not an attack on religious freedom. Congress could fix this by amending RLUIPA or passing new legislation under a broader constitutional power.

Sources:

[1] Web – Did Justice Jackson Lose The Majority In Landor To Justice Gorsuch?

[3] Web – Landor v. Louisiana Department of Corrections – Oyez

[11] Web – CAC Release: Supreme Court’s Conservative Supermajority …