Supreme Court Blocks Rastafarian’s Suit Against Prison Officials

The Supreme Court says state prison officials can’t be sued in their personal capacities for violating inmates’ faith under a federal religious freedom law.

In a 6-3 decision on Tuesday, the court said state employees didn’t consent to face lawsuits in their personal capacities when Congress passed the Religious Land Use and Institutionalized Persons Act of 2000.

“Under the Spending Clause, Congress lacks regulatory authority to impose liability on them directly and must depend instead on consent,” Justice Neil Gorsuch wrote for the court.

The petitioner, Damon Landor, sought to sue corrections officers under RLUIPA after he was pinned down and forcibly shaved in a Louisiana prison in violation of his Rastafarian faith.

The court’s three liberal justices dissented from the opinion. In a dissent, Justice Ketanji Brown Jackson said the court’s holding “magically transforms” a federal statute into an “invitation to be accepted or declined.”

The decision marks a rare loss for religious liberty interests, which have notched a string of recent victories at the court.

The court’s conservatives, usually amenable to claims from religious litigants, were more concerned with whether state employees received appropriate notice that they could be personally liable under a federal religious liberty law.

RLUIPA is a 2000 law that filled gaps left at the state level by its more well-known sister statute, the Religious Freedom Restoration Act.

In 2020, the Supreme Court held in Tanzin v. Tanvir that RFRA allows individual damages suits against federal officials for religious liberty violations.

The Supreme Court agreed to hear his case after the US Court of Appeals for the Fifth Circuit said his suit was barred by existing precedent.

The case is Landor v. Louisiana Department of Corrections and Public Safety, U.S., No. 23-1197, 6/23/26.