Legal Issue(s): NA
Case Description
In 2020, Louisiana state prison guards handcuffed a Rastafarian prisoner, held him down, and then shaved his lifelong growth of hair even though the inmate (Landor) had religious beliefs and prior accommodations. The 5th Circuit Court of Appeals condemned the guards’ actions but followed circuit precedent saying that damages are not available to Landor. The en banc court denied review, but 15 of the 17 active judges (in concurrences and dissents) noted that Tanzin v. Tanvir, 592 U.S. 43 (2020), had or might have undercut the circuit precedent and that the U.S. Supreme Court should address the question.
The question in the case is whether the Religious Land Use and Institutionalized Persons Act (RLUIPA) authorizes damages suits against state officers in their individual capacities. The Fifth Circuit said no, but in June, Landor succeeded in getting the Supreme Court to hear his case.
The Center just filed an amicus brief supporting the plaintiff’s claim that RLUIPA does authorize such damage suits in Landor v. Louisiana Dept. of Corrections. A win in this case would add a layer of accountability to state actors who violate the rights of those in their custody, likely causing them to seek a second opinion before proceeding with any questionable actions. Oral arguments are expected sometime during the Court’s 2025 fall term.
