No Way to Enforce Religious Rights: Landor v. Louisiana

Damon Landor came prepared. A Rastafarian who had grown his hair for nearly twenty years as an act of faith arrived at a Louisiana prison holding a printed copy of a federal court ruling that stated plainly: prisons cannot cut a Rastafarian’s hair. The intake guard threw it in the trash. Soon after, two officers handcuffed Mr. Landor to a chair, held him down, and shaved his head.    

Mr. Landor had done everything the law asked of him. He knew his rights, he carried the proof, and he placed it in the hands of the very people sworn to follow it. None of it mattered. On June 23, 2026, the Supreme Court told Damon Landor he could do nothing about it. 

In Landor v. Louisiana Department of Corrections and Public Safety, the Supreme Court, in a 6-3 majority, held that prisoners cannot sue individual officers for monetary damages under the Religious Land Use and Institutionalized Persons Act (RLUIPA). RLUIPA safeguards the religious practices of incarcerated individuals, including the rights to pray, maintain a beard or uncut hair, wear a hijab, and consume halal food. For two decades, it has served as the most robust protection for Muslim prisoners.  

The Supreme Court did not contest that Mr. Landor’s rights were violated. However, it held that RLUIPA, as legislation based on Congress’s spending power, functions similarly to a private contract. While Louisiana accepted federal funds and agreed to RLUIPA’s terms, the individual officers did not. Consequently, the Court reasoned that the officers responsible for shaving Mr. Landor’s head could not be held personally accountable for their actions.   

This decision has significant implications. In 2011, Sossamon v. Texas established that prisoners could not recover damages from the state under RLUIPA. The Landor decision eliminates the remaining avenue for state prisoners: obtaining damages directly from individual officers. Although a prisoner can still ask a court to order better treatment through injunctive relief, the moment he is transferred or released, that request becomes moot and is no longer enforceable. That is exactly what happened to Mr. Landor. The officers responsible face no consequences, while the individual whose rights and faith were violated is left with an unenforceable right and no avenue to justice.   

At MLFA, we have dedicated twenty-five years to defending the religious freedom of Muslims, including those behind bars, where that freedom is most fragile and most often ignored.  MLFA, along with other religious and non-profit organizations, filed an amicus brief in support of Mr. Landor before the Supreme Court. When an officer can disregard a court order, strip a man of his faith, and face no consequence, the law meant to protect that man becomes nothing but a mere suggestion, and the people who feel that first are those with the least power to be heard.  

The reach goes beyond prison walls. RLUIPA is one of many federal protections built on Congress’s spending power, from civil rights to healthcare to education, and the Court’s logic treats them all as bargains rather than commands. While Landor did not directly strike down those laws, it quietly weakened the ground on which they stood.  

The Constitution rarely fails all at once. It often fails quietly, one unenforceable right at a time. Landor is one of those quiet failures, and the people who will feel it are the ones who can least afford to be told that their rights exist only on paper.