Supreme Court Bars Damages for Forcibly Shaved Dreadlocks, Creating Two-Tier Religious Liberty

On June 23, 2026, the Supreme Court closed the courthouse door to prisoners whose religious rights are violated behind bars. In Landor v. Louisiana Department of Corrections and Public Safety, the Court held that the Religious Land Use and Institutionalized Persons Act (RLUIPA) does not permit lawsuits for monetary damages against state officials in their individual capacities. The facts are visceral: Damon Landor, a Rastafarian inmate who had grown dreadlocks for nearly two decades as a tenet of his faith, was handcuffed to a chair by prison guards and forcibly shaved. He did not voluntarily cut his hair—he was physically restrained and his hair removed against his will. Yet under the Court's ruling, he and countless similarly situated prisoners have no remedy beyond an injunction, which may never be enforced.

This outcome sits in stark contrast to the Court's treatment of religious liberty in other contexts. In Groff v. DeJoy (2023), the Court issued a 9-0 decision (Justice Alito writing for a unanimous Court; Justice Sotomayor filed a concurring opinion joined by Justice Jackson). That ruling strengthened religious accommodation protections for postal workers under Title VII, making it harder for employers to deny accommodations. The Landor decision reveals a two-tier system: robust religious freedom for those with political or economic power—including businesses invoking exemptions—and hollow protections for the incarcerated. For civil rights litigators, this weakens a key deterrent against religious discrimination in prisons and leaves prisoners dependent on injunctive relief that is difficult to obtain and monitor. The threat of financial liability is gone; the incentive to comply now rests on coercion alone.