The Supreme Court ruled 6-3 that former Louisiana inmate Damon Landor cannot pursue individual damages against state prison officials under RLUIPA after guards shaved his dreadlocks. The decision, authored by Justice Gorsuch, upheld the Fifth Circuit and held that states accepting federal funds did not consent to such suits against employees. Three liberal justices dissented.
The 6-3 decision erects procedural barriers that shield officials from accountability for violating prisoners' religious liberties, disproportionately affecting marginalized inmates.
“Power imbalance favoring institutions over individual rights”
Conservative
The ruling correctly limits federal overreach by barring damages suits against state employees under a Spending Clause statute and preserves prison authority over operations.
“Federalism and institutional control over day-to-day prison management”
Libertarian
The textual application of RLUIPA respects constitutional limits on federal power while highlighting the lack of remedies when state agents violate religious practice.
“Constraints on enumerated powers and individual liberty against government coercion”
Devil's Advocate
All perspectives accept the Spending Clause framing without examining prison policy details, alternative remedies, or whether the merits of the religious burden were addressed.
“Overlooked operational realities and incomplete analysis of available legal avenues”