The Supreme Court said on Monday that it would decide whether a Rastafarian man may sue prison guards in Louisiana who shaved off his dreadlocks in seeming violation of an appeals court’s ruling about how the state must treat members of his faith.
The case concerns Damon Landor, whose faith requires him to let his hair grow long. When he started a five-month prison term for drug possession in Louisiana in 2020, his dreadlocks fell nearly to his knees.
Mr. Landor was wary of the state’s prison system, according to a lawsuit he later filed, and he kept a copy of a 2017 judicial decision with him. That ruling, from a unanimous three-judge panel of the U.S. Court of Appeals for the Fifth Circuit, said that Rastafarian inmates in Louisiana must be allowed to keep their dreadlocks under a 2000 federal law protecting prisoners’ religious freedom.
The first four months of Mr. Landor’s incarceration were uneventful. Then he was transferred to the Raymond Laborde Correctional Center in Cottonport, La. According to his lawsuit, he presented a copy of the 2017 decision to a guard, who threw it in the trash.
After consulting the warden, two guards handcuffed Mr. Landor to a chair, held him down and shaved his head to the scalp.
“When I was strapped down and shaved, it felt like I was raped,” Mr. Landor said in a statement last year. “And the guards, they just didn’t care. They will treat you any kind of way. They knew better than to cut my hair, but they did it anyway.”
The question the justices agreed to decide is whether the 2000 religious freedom law allows suits against prison officials for money.
The case is in an early stage, and courts have assumed that Mr. Landor’s account of what happened to him is true. Officials in Louisiana have so far not disputed it.
Elizabeth B. Murrill, Louisiana’s attorney general, agreed that the conduct Mr. Landor described was appalling, but she said the 2000 law did not allow his suit.
“The allegations in petitioner’s complaint are antithetical to religious freedom and fair treatment of state prisoners,” Ms. Murrill wrote in a brief urging the justices to deny review. “Without equivocation, the state condemns them in the strongest possible terms.”
She added that “the state has amended its prison grooming policy to ensure that nothing like petitioner’s alleged experience can occur.”
Last month, the Trump administration filed a supporting brief urging the justices to hear Mr. Landor’s case and to rule that he may pursue his suit.
Mr. Landor’s case does not seem to be an outlier. At least five other Rastafarians have filed lawsuits in Louisiana saying their dreadlocks were forcibly shaved by prison officials.
Mr. Landor sued the warden and the guards under the 2000 law, the Religious Land Use and Institutionalized Persons Act. When the case reached the Fifth Circuit, the same court that had ruled that the law protected Rastafarian prisoners’ dreadlocks, a different three-judge panel said that “we emphatically condemn the treatment that Landor endured.”
But that condemnation was all the relief the panel was willing to offer Mr. Landor. It ruled that he was still not entitled to sue the prison officials for money because the 2000 law had not specifically authorized such suits.
In his petition asking the Supreme Court to hear his case, Mr. Landor said the Fifth Circuit’s ruling was at odds with a 2020 decision interpreting identical language in the Religious Freedom Restoration Act of 1993.
In that case, the court ruled in favor of Muslim men who said their religious rights had been violated when F.B.I. agents put them on the no-fly list in retaliation for refusing to become government informants.
The court did not find the question of whether they could sue for money difficult. In a brisk nine-page opinion for a unanimous court in 2020 in the case, Tanzin v. Tanvir, Justice Clarence Thomas wrote that “in the context of suits against government officials, damages have long been awarded as appropriate relief.”
In Mr. Landor’s case, the Fifth Circuit ruled that the 2000 law, which applies to the states, was meaningfully different from the 1993 law, which, after the Supreme Court limited its sweep, applies only to the federal government.
The full Fifth Circuit declined to rehear the panel’s ruling. But nine judges in the majority urged the Supreme Court to clarify matters in the case, Landor v. Louisiana Department of Corrections and Public Safety, No. 23-1197.
Prison officials, Judge Edith Brown Clement wrote, “knowingly violated Damon Landor’s rights in a stark and egregious manner, literally throwing in the trash our opinion holding that Louisiana’s policy of cutting Rastafarians’ hair violated the Religious Land Use and Institutionalized Persons Act before pinning Landor down and shaving his head. Landor clearly suffered a grave legal wrong.”
But whether he can sue prison officials for money, Judge Clement wrote, “is a question only the Supreme Court can answer.”
Adam Liptak covers the Supreme Court and writes Sidebar, a column on legal developments. A graduate of Yale Law School, he practiced law for 14 years before joining The Times in 2002.
The post Supreme Court to Hear Rastafarian Prisoner’s Suit Over Shaved Dreadlocks appeared first on New York Times.
