The lawsuit appeal of Damon Landor, a former Louisiana prisoner and ardent Rastafarian, whose dreadlocks were forcibly shaved by prison officials,was accepted by the Supreme Court on June 23. 

Landor was required to refrain from cutting his hair due to his religious commitment, which is known in the Rastafari tradition as the Nazarite Vow. He’s worn the hairstyle for more than 20 years. 

He had successfully kept his locks in two state prisons and was nearing the end of a five-month sentence for drug possession in 2020. But things changed when he was moved to Raymond Laborde Correctional Center in Cottonport, Louisiana, for his last three weeks. 

In addition to providing documentation of previous religious accommodations and a 2017 Fifth Circuit court ruling that found Louisiana's practice of cutting Rastafarians' hair to be a violation of the Religious Land Use and Institutionalized Persons Act (RLUIPA), Landor disclosed his faith to a guard upon admission. 

That precedent declared Louisiana's haircut requirement unconstitutional. According to reports, Landor carried a copy of the law with him to support his stance, but the document was thrown in the trash by a guard before ordering other prison guards to physically restrain Landor, handcuff him to a chair, and shave his head to the scalp. 

After being released, Landor sued the officials involved under RLUIPA, requesting monetary damages. Since RLUIPA prohibits damage claims against individuals, a federal district court dismissed the case. A Fifth Circuit appeals panel upheld the dismissal in 2023, strongly denouncing the forced haircut but claiming that precedent precluded individual liability under the Act. 

With six judges in favor and eleven against, an attempt to rehear the case en banc—a session where all judges of a court, rather than a smaller panel, hear a case— was unsuccessful. 

According to Landor's attorneys, RLUIPA ought to allow individual-damage lawsuits, just like its statutory sibling the Religious Freedom Restoration Act (RFRA). They point to the 2020 Supreme Court decision Tanzin v. Tanvir, which allowed damages against federal officials under the RFRA, as precedent. 

Although they back the review, Louisiana officials insist that RLUIPA does not permit individual lawsuits. In addition to denouncing the forced haircut and amending its prison grooming policy, the state warns that permitting damages could put a strain on prison staffing across the country. 

During the Court's term, which starts in October 2025, Landor v. Louisiana Department of Corrections, No. 23-1197, will be heard. A decision is anticipated by June 2026. 

If this case clarifies whether individual officials can be held financially accountable under RLUIPA, it could be a significant turning point in the jurisprudence surrounding religious freedom behind bars.