Damon Landor, a devout Rastafarian who follows the religion's Nazarite Vow against cutting one's hair, cannot seek monetary damages under the Religious Land Use and Institutionalized Persons Act from 10 guards and the former warden of Raymond Laborde Correctional Center in Cottonport, Louisiana, for handcuffing him to a chair and shaving his head over his objections in 2020, the justices ruled in a 6-3 decision.
RLUIPA, which prohibits state and local governments that receive federal funding from regulating land and institutions in a way that discriminates based on religion, doesn't authorize lawsuits against government officials in their personal capacities unless they "voluntarily and knowingly consented" to be held liable under the law, unlike its "twin" statute that prohibits religious discrimination on the federal level, Justice Neil Gorsuch wrote for the court.
Since the individual guards named in Landor's case didn't sign individual contracts with the federal government acknowledging they could be held liable under the law, no cause of action exists, Justice Gorsuch said. However, Landor may still be able to bring federal claims against the Louisiana Department of Corrections and Public Safety as their employer, or state claims against the individual guards.
"Under the spending clause, Congress lacks regulatory authority to impose liability on them directly and must depend instead on consent," he said of the guards. "And because they never agreed to answer suits like this one, Mr. Landor's case cannot proceed against them any more than a breach of contract might proceed against a defendant who never formed a contract."
Tuesday's ruling is distinct from the Supreme Court's 2020 decision in Tanzin v. Tanvir
, which determined the Religious Freedom Restoration Act — RLUIPA's federal sister statute — allows plaintiffs to pursue claims against federal officials in their individual capacities.While the majority never cites the Tanzin decision, Justices Sonia Sotomayor, Elena Kagan and Ketanji Brown Jackson argue in dissent that the earlier case should control the outcome in Landor's. Instead, Justice Jackson writes for the trio, that the majority'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."
"The majority's analysis is spellbindingly straightforward: spending clause statutes are contracts, and contracts bind only those who consent," she wrote. "But pulling this rabbit out of the hat requires misconstruing the spending clause and the necessary and proper clause, and ignoring decades of precedent affirming Congress's authority to use the power of the purse to govern."
"In the end," she adds, "the court reduces 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."
Louisiana Attorney General Liz Murrill said in a statement Tuesday the state condemns what happened to Landor and has taken steps to prevent similar incidents in the future, but is ultimately happy the Supreme Court agreed with the state on the question of individual liability.
"Religious liberty is deeply important, and Louisiana has laws on the books protecting it," she said. "Ten federal courts of appeals held that the federal Religious Land Use and Institutionalized Persons Act does not allow prisoners to sue prison officials in their personal capacities for damages, and now the Supreme Court has agreed."
Meanwhile, Landor's attorney, Weil Gotshal & Manges LLP partner Zack Tripp, described the high court's decision as deeply disappointing.
"It means that inmates whose religious rights are violated by state prison officials will have no damages remedy no matter how egregious the wrong," Tripp said. "But we are encouraged by the awareness the case has raised about this important issue, and we are deeply thankful for the support [Landor] has received in his fight."
Tripp added the opinion provides "a glimmer of hope" by exploring the ways Congress could fix or amend RLUIPA in the future.
Landor's lawsuit arises from his August 2020 transfer to the Raymond Laborde Correction Center just weeks before he was scheduled to finish a five-month prison sentence for drug possession charges.
According to court documents, when he arrived at the facility, Landor objected to the mandatory haircut, showing the prison guards a copy of a Fifth Circuit decision in favor of a fellow Rastafarian that had found the Louisiana Department of Corrections and Public Safety's prohibition on inmates having dreadlocks was unlawfully burdensome under RLUIPA.
But the guards proceeded with the haircut. They threw away Landor's copy of the Fifth Circuit opinion, handcuffed him to a chair and forcibly shaved his head.
After his release, Landor sued the prison guards and Raymond Laborde's then-warden, seeking monetary damages from each of them in their individual capacities. However, a Louisiana federal judge dismissed his case under Fifth Circuit precedent that bars individual capacity RLUIPA lawsuits for monetary damages.
A unanimous three-judge Fifth Circuit panel affirmed the ruling while "emphatically" condemning Landor's treatment. The panel held that Congress had enacted RLUIPA under its spending clause power, so only the recipient of federal funding — Louisiana in this case — can be held liable for violating the act.
Justice Gorsuch and the Supreme Court's conservative supermajority agreed with the Fifth Circuit's decision Tuesday, likening RLUIPA to a contract between the federal government and Louisiana. Court precedents dating back to at least 1845 support that conclusion, the court said.
"If someone has not agreed to be bound, it does not matter that he may be aware of the existence of a contract between other parties," Justice Gorsuch wrote. "And if someone has not agreed to be bound, it does not matter whether other contracting parties might wish to bind him. Either way, he has not agreed to be bound, so he cannot be."
The majority added that while suits like Landor's might advance RLUIPA's protection of religious exercises, they do nothing to "safeguard from graft" the distribution of federal funds that is at the center of Congress' spending power.
But where the spending power falls short, Justice Jackson argues, the necessary and proper clause provides Congress the authority to enforce RLUIPA against individuals.
"Where an enumerated power enables Congress to prescribe rules, the necessary and proper clause empowers Congress to 'give those rules force by imposing consequences on [those] who disobey them,'" she said.
Additionally, Justice Jackson said, the Supreme Court has never used the spending power-to-contract analogy in the way it does in Landor's case. The court used the analogy in "relatively modest ways," in previous decisions but now "abandons its warranted caution," she said.
"So the court's ruling apparently boils down to dissatisfaction with the precise way Congress structured RLUIPA," Justice Jackson said. "Such hairsplitting undervalues Congress's lawmaking prerogative; we ought not substitute our rigid contract-based preferences for Congress's considered statutory design."
Landor is represented by Zachary D. Tripp, Joshua M. Wesneski, Rachael E. Jones, Laurel L. Zigerelli, Sarah M. Sternlieb, Natalie Howard and Tiffany Kim of Weil Gotshal & Manges LLP and Casey Denson.
The Louisiana Department of Corrections and Public Safety is represented by J. Benjamin Aguiñaga, Zachary Faircloth, Morgan Brungard, Kelsey L. Smith, Caitlin A. Huettemann and Elizabeth Brown of the Louisiana Department of Justice.
The case is Landor v. Louisiana Department of Corrections and Public Safety et al., case number 23-1197, in the Supreme Court of the United States.
--Editing by Alyssa Miller.
Update: This story has been updated to include additional information from the ruling and comments from counsel.
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