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Supreme Court rules against Rastafarian who sued prison officials for cutting his dreadlocks

By John Fritze and Devan Cole, CNN

(CNN) — The Supreme Court on Tuesday ruled that a devout Rastafarian who attempted to sue prison officials for holding him down and cutting his dreadlocks could not proceed with his case, a decision that will make it harder for believers of other faiths to enforce federal religious protections in prison.

The opinion, written by Justice Neil Gorsuch for a 6-3 court, marked a rare instance in which the conservative majority sided against a religious claim and underscored its hesitancy to let Americans sue to enforce their rights without explicit authority from Congress.

“Mr. Landor would have us hold, for the first time, that so long as a penny of federal spending makes its way to an individual, however indirectly, Congress can regulate his conduct directly based on the fiction that he has consented to regulation,” Gorsuch wrote. “None of that is consistent with our precedents.”

The court ruled that the man at the center of the case, Damon Landor, could not sue state officials over his treatment because local officials were not aware of the details of a federal law that protects religion.

Justice Ketanji Brown Jackson, writing for the court’s three liberals, criticized the majority for what she saw as a decision to weaken the federal law under which Landor was attempting to sue. The court’s move, Jackson wrote, will make it much more difficult for prisoners to drag officials to court over allegations that their rights have been impugned.

“Prisoners like Landor who suffer violations of their religious freedom in state prisons – no matter how blatant – will often be left remediless,” Jackson wrote. “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.”

Jackson asserted that the court’s rationale effectively reduced “some of Congress’s greatest legislative achievements — federal laws that secure civil rights, environmental stability, healthcare, and more — to nothing more than the wheelings-and-dealings of an especially wealthy private party.”

Guards threw a previous decision in the trash before holding him down

Landor had a few weeks left in his sentence for drug possession when guards at a Louisiana prison handcuffed him to a chair and shaved off the knee-length dreadlocks he had grown over nearly two decades. Minutes earlier, Landor had handed his guards a judicial opinion demonstrating that they were required to allow dreadlocks for religious purposes.

The guards tossed that opinion in the trash before holding Landor down and cutting his hair.

He was incarcerated without incident at two other facilities before he was transferred to the Raymond Laborde Correctional Center. He came armed with a copy of an appeals court ruling from 2017 that allowed prisoners to have dreadlocks.

Landor, who began serving a five-month prison sentence in 2020, had previously taken a promise known as the Nazarite vow to not cut his hair.

Landor’s case at the Supreme Court rested on the Religious Land Use and Institutionalized Persons Act, or RLUIPA. Congress passed that law, and another that dealt with religious accommodation more widely, in response to a landmark but controversial 1990 precedent from the court.

In late 2020, the justices ruled that the other law, which has nearly identical language, allows people whose religious rights have been burdened to seek damages against government officials acting in their individual capacity.

But Louisiana countered that RLUIPA is effectively a spending contract between state officials and the federal government, which provides funding for state prisons. The individual officials involved in Landor’s forced shaving were not parties to that contract, Louisiana said, so they can’t be held personally liable.

A panel of the conservative 5th US Circuit Court of Appeals ruled that Landor was not entitled to sue.

The 5th Circuit said that it “emphatically” condemned “the treatment that Landor endured,” but an earlier appeals court precedent settled the case against him. The full appeals court ultimately decided against rehearing the case and Landor appealed to the Supreme Court in 2024.

Case seemed tailor-made for conservative court

On the one hand, the case appeared designed for a Supreme Court that has consistently sided with religious interests in recent years. Last year, the court sided with a group of religious parents who wanted to opt their children out of books dealing with LGBTQ themes in elementary school.

In 2022, it backed a high school football coach who had been removed from his job for praying on the field before games.

A year before that, it allowed a Catholic foster care agency to continue to work for the city of Philadelphia even though it declined to screen same-sex couples as potential foster parents.

Rachel Laser, the president and CEO of Americans United for Separation of Church and State, described the decision as hypocritical.

“Once again, we see a court that will bend over backward for the religious freedom of Christians but allows the government to trample the religious freedom of non-Christians,” said Laser, whose group frequently opposes decisions from the Supreme Court that back religious interests.

This story has been updated with additional details.

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