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In 2020, Damon Landor, a Rastafarian who had taken the Nazarite Vow promising not to cut his hair, was held down and shaved by guards at a correctional facility in Louisiana. Following his release, Landor sued Louisiana prison officials under the Religious Land Use and Institutionalized Persons Act (RLUIPA), a federal law protecting the religious rights of incarcerated people. In Landor v. Louisiana Department of Corrections, issued today, the Supreme Court held that state prison employees cannot be sued for money damages under RLUIPA without their consent—even when a religious liberty violation is undisputed. The ruling leaves incarcerated people whose religious rights are violated without a meaningful avenue for accountability. LRRP Director Liz Reiner Platt’s new op-ed in Religion News Service uses the case to examine how religious rights are shaped and limited by a variety of legal doctrines—including qualified and sovereign immunity, the Prison Litigation Reform Act, and nonreviewability rules—that systematically disadvantage the most vulnerable claimants. As Platt writes, this is not a deviation from the Court’s expansive view of religious liberty–it’s a longstanding pattern.
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