For greater than 20 years, the Ideal Court docket has issued an extended collection of wins for plaintiffs in search of to offer protection to their spiritual practices. On June 23, 2026, although, the bulk delivered an unusual defeat on this contentious space.
Landor v. Louisiana Division of Public Schooling and Protection, a 6-3 judgment, rejected the declare of Damon Landor, a Rastafarian whose hair was once forcibly shaved in jail. Landor had worn lengthy dreadlocks for nearly two decades as an expression of his ideals – a part of a biblical observe referred to as the “Nazarite vow.”
Like decrease courtroom judges, the Ideal Court docket didn’t dispute that officers violated Landor’s rights. Alternatively, the excessive courtroom’s majority dominated that he may just now not sue particular person officers on the jail.
The case stands proud for a minimum of 3 different causes.
First, Landor v. Louisiana underscores the complexity and far-reaching nature of non secular freedom rules in america and the more and more various religion traditions to which they observe. Christians now constitute 62% of the American inhabitants, down from 78% in 2007, whilst 29% haven’t any spiritual association and seven% belong to different religion traditions.
2nd, Landor’s case won make stronger from many teams most often at odds over how to offer protection to spiritual freedoms – teams dissatisfied with this week’s choice.
In the end, the case highlights the spiritual rights of the just about 2 million other folks in U.S. prisons, jails and detention and correctional amenities – and the problem of maintaining their public workers responsible when the ones rights are violated.
Non secular vow
Landor was once incarcerated in Louisiana in 2020 for possessing methamphetamine, cocaine, amphetamine and marijuana.
To start with, officers revered his spiritual observe. Simply 3 years previous, a federal appeals courtroom affirmed that Rastafarian inmates should be allowed to stay their dreadlocks below a federal regulation handed in 2000: the Non secular Land Use and Institutionalized Individuals Act.
As an indication of religion, many Rastafarians don’t minimize their hair.
Mattstone911/Wikimedia Commons, CC BY-SA
Towards the tip of his sentence, Landor was once transferred to another correctional facility within the state. There – with 3 weeks left for Landor to serve – the warden unnoticed the judicial order, directing guards to shackle Landor and forcibly shave his head.
After completing his sentence, Landor filed swimsuit for cash damages below the Non secular Land Use and Institutionalized Individuals Act. The act forbids the federal government and its officers from enforcing “substantial burden(s)” on incarcerated other folks’s First Modification proper to the unfastened workout of faith. It additionally protects spiritual teams from discrimination thru zoning restrictions.
Adventure throughout the courts
In 2022, a federal trial courtroom in Louisiana condemned Landor’s remedy however rejected his declare, concluding that cash damages weren’t a suitable treatment below the act.
The next 12 months, the fifth U.S. Circuit Court docket of Appeals “emphatically condemn(ed) the treatment that Landor endured.” Alternatively, the panel unanimously affirmed the decrease courtroom’s choice, in response to its previous ruling that plaintiffs can not sue govt officers of their particular person capacities for financial damages – handiest the establishment.
Landor’s lawyers then sought an “en banc” listening to. On this unusual process, events search additional evaluate through all the judges in a federal circuit. The courtroom denied this request, as a majority of judges within the circuit wrote that this was once a query for the Ideal Court docket.
The Ideal Court docket agreed to listen to an enchantment after a lot of organizations, together with the government, submitted amicus curiae, or “friend of the court,” briefs in prefer of Landor. Those integrated American citizens United for Separation of Church and State, as an example, which most often helps plaintiffs wishing to stay faith out of public lifestyles. Additionally they integrated the Becket Fund, which typically represents other folks in search of to extend religion’s position in public lifestyles, and the Trump management.
At factor was once now not whether or not Landor’s rights were violated however whether or not he may just sue a person professional, specifically the warden, for financial damages. Throughout oral arguments on Nov. 10, 2025, the Ideal Court docket appeared skeptical.
Criminal predicament
That skepticism was once mirrored within the courtroom’s final ruling. It was once necessarily a procedural ruling concerning the Non secular Land Use and Institutionalized Individuals Act quite than a judgment at the deserves of Landor’s spiritual freedom declare.
Justice Neil Gorsuch wrote the bulk opinion, joined through Leader Justice John Roberts and Justices Clarence Thomas, Samuel Alito, Brett Kavanaugh and Amy Coney Barrett. Justice Ketanji Brown Jackson’s dissent was once joined through Justices Sonia Sotomayor and Elena Kagan.
U.S. Ideal Court docket justices attend inauguration ceremonies within the rotunda of the U.S. Capitol on Jan. 20, 2025.
Chip Somodevilla/Getty Pictures
The bulk’s argument that Landor may just now not sue focused at the spending clause of the U.S. Charter – the supply of Congress’ authority to create the Non secular Land Use and Institutionalized Individuals Act. The spending clause permits the legislature to spend cash to offer for the “general Welfare of the United States.” If a state or establishment makes use of federal finances, their officers conform to positive stipulations; in the event that they violate the ones stipulations, Congress can take away investment.
However the spending clause does now not give Congress authority to carry particular person workers responsible, Gorsuch argued in his 18-page opinion. Jail officers had now not “voluntarily and knowingly consented to answer private suits” below the act, and they may just now not be held without delay accountable for financial damages. Differently, Congress would have “effectively unbridled police power.”
Jackson’s 29-page dissent disagreed with the bulk’s interpretation of the spending clause. The ruling, she contended, “jettisons ‘a long line of this Court’s precedents’” below which “Congress has been able to use its spending power to reach beyond direct recipients of federal funds.” As such, she anxious that the courtroom’s order imposed a “novel consent requirement.”
Jackson additionally lamented the verdict’s attainable penalties for inmates. Even supposing the objective of the Non secular Land Use and Institutionalized Individuals Act was once to offer protection to prisoners’ religion practices, she anxious that individuals “like Landor who suffer violations of their religious freedom in state prisons – no matter how blatant – will often be left remediless.”
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At a look, the Landor case seems to be a procedural confrontation quite than one over spiritual freedom.
Alternatively, I argue Landor v. Louisiana should be seen as a setback for spiritual liberty, elevating a significant query about whether or not minority faiths have as a lot coverage below the First Modification as higher religions. The verdict may be one thing of a wonder to me, for the reason that Ideal Court docket has not too long ago upheld unfastened workout rights in more than one high-profile circumstances, nearly all of which contain Christianity – equivalent to a soccer trainer’s talent to wish at the box after public college video games.
Parts of this text firstly gave the impression in a prior article printed on Nov. 6, 2025.
