Damon Landor has become the center of a dispute over religious freedom for prisoners in the United States. Landor is a devout Rastafarian who had grown his dreadlocks for more than 20 years as part of his religious practice, making his hair long enough to reach his knees. On Tuesday, June 23, Landor unsuccessfully asked the U.S. Supreme Court to allow him to sue prison guards for shaving his head.
Rastafarianism is an Afrocentric spiritual and cultural movement that traces its roots to Jamaica in the 1930s. Followers, often called “Rastas,” regard it as a complete religion with spiritual practices that shape their philosophy of life. One such practice is the growing of dreadlocks, which symbolize spirituality and separation from what adherents call Babylon.
Landor anticipated issues
Back in 2020, Landor was nearing the end of a five-year prison sentence for drug possession when he was transferred to another institution in Cottonport, Louisiana, the Raymond Laborde Correctional Center. By that point, Landor already anticipated that his hair could become an issue and arrived prepared with a legal precedent.
In 2017, the New Orleans-based Fifth U.S. Circuit Court of Appeals ruled that cutting a Rastafarian prisoner’s dreadlocks violated the Religious Land Use and Institutionalized Persons Act (RLUIPA) of 2000. The law protects the religious rights of people held in prisons, jails, and detention facilities.
Landor reportedly handed a printed copy of that ruling to prison guards, telling them that cutting his hair would violate the law. Landor claims the guards threw the ruling into the trash, handcuffed him to a chair, and shaved his head. According to The Guardian, Landor later said, “When I was strapped down and shaved, it felt like I was raped.”
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After his release, Landor sued the prison guards, but a federal judge dismissed his case. In 2023, an appeals court upheld that decision, ruling that the law does not extend liability to individual officials and that prison employees cannot be personally sued for alleged violations of Landor’s religious rights.
The Supreme Court had previously allowed for monetary claims
The case eventually reached the Supreme Court, where Landor’s attorneys pointed to a 2020 ruling that allowed monetary claims under RLUIPA. That case stemmed from three American Muslim men who sued the FBI after being placed on a no-fly list because they refused to become informants.
Still, Chief Justice John Roberts and Justices Clarence Thomas, Samuel Alito, Brett Kavanaugh, and Amy Coney Barrett upheld the lower court’s decision to dismiss Landor’s case. Three justices, however, dissented. According to The Guardian, Justice Ketanji Brown Jackson wrote that prisoners “like Landor who suffer violations of their religious freedom in state prisons – no matter how blatant – will often be left remediless. And encroachments on prisoners’ statutory rights are likely to happen with fair frequency, as state-empowered prison officials will have little incentive to abide by federal law, even if it is handed to them on a piece of paper.”
Landor did receive some support from the Donald Trump administration, which urged the court to consider reviving the case for further deliberations.
