The Supreme Court ruled Tuesday that prison inmates cannot sue individual state prison employees for damages under the Religious Land Use and Institutionalized Persons Act (RLUIPA). In a 6-3 decision, the Court concluded that while the federal statute allows for legal action against state prison systems, it does not authorize private lawsuits against the officials who work for them. The ruling effectively limits the remedies available to incarcerated individuals seeking to enforce their religious rights.
### Why the Supreme Court ruled against individual liability
Writing for the majority, Justice Neil M. Gorsuch explained that the federal government’s authority to impose conditions on states through RLUIPA is tied to the receipt of federal funding. Because RLUIPA functions as a condition for states accepting federal money, the Court determined it does not create a direct cause of action against individual prison staff members.
“To know that is enough to know the Court of Appeals was correct,” Justice Gorsuch wrote in the majority opinion. “Mr. Landor does not have a federal RLUIPA cause of action against the officers. Congress lacks regulatory authority to impose liability on them directly.” The decision affirmed the stance taken by the 5th U.S. Circuit Court of Appeals, which had previously dismissed the lawsuit filed by Damon Landor, a Louisiana inmate.
### The case of Damon Landor
The litigation stemmed from an incident involving Damon Landor, a practicing Rastafarian who had maintained dreadlocks for nearly two decades. According to court filings, Landor was transferred between Louisiana facilities with only three weeks remaining in his five-month sentence. Despite possessing a federal appeals court opinion affirming the right of Rastafarian inmates to wear dreadlocks, Landor was ordered by a warden to have his hair forcibly shaved. Prison guards handcuffed Landor to a chair to facilitate the procedure. Upon his release, Landor sued the warden and the guards, arguing the act violated RLUIPA’s mandate for “appropriate relief” regarding religious exercise.
### The dissenting perspective
The three liberal justices—Ketanji Brown Jackson, Sonia Sotomayor, and Elena Kagan—dissented from the majority’s ruling. Justice Jackson authored the dissent, arguing that the Court’s interpretation leaves incarcerated individuals without recourse when their constitutional religious freedoms are violated.
“Today’s decision magically transforms a federal statute into an invitation to be accepted or declined, deemed binding only if each particular defendant has explicitly agreed to be penalized,” Justice Jackson wrote. She contended that the ruling leaves prisoners like Landor effectively remediless, even in cases of blatant religious rights violations.
### Consequences for civil rights protections
Civil liberties organizations have expressed significant concern regarding the impact of this decision on the incarcerated population. Rachel Rossi, president of the Alliance for Justice, stated that the ruling erodes the accountability necessary to protect civil rights. Similarly, Rachel Laser, the chief executive of Americans United for Separation of Church and State, suggested that the decision creates a disparity in how religious freedom is upheld, particularly for non-Christians within the prison system.
The ruling establishes a clear legal standard: while the federal government may hold state institutions accountable for religious liberty violations, individual employees remain shielded from private suits for damages under RLUIPA. This distinction narrows the available legal avenues for inmates seeking compensation for the infringement of their religious practices.
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