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Landor v. Louisiana Department of Corrections and Public Safety

United States Supreme Court
146 S. Ct. 1931 (2026)

Written by Jamie Milne, JD

Facts

The Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), enacted under Congress’s Spending Clause authority, imposed certain conditions on the receipt of federal funding by state prison systems. Specifically, RLUIPA required that systems not substantially burden prisoners’ religious exercise. It also required that systems agree to be subject to private suits for RLUIPA violations. The Louisiana Department of Corrections (LDOC) (defendant) was a funding recipient subject to RLUIPA’s conditions. LDOC prisoner Damon Landor (plaintiff) was a Rastafarian whose religious beliefs required that he not cut his hair. Nevertheless, LDOC officers forcibly shaved Landor’s head. After being released, Landor sued the LDOC and several LDOC officers (defendants) in their individual capacities for violating RLUIPA. The officers moved to dismiss the claim against them, arguing the claim was not viable because they never agreed to be subject to private suits under RLUIPA. The district court dismissed Landor’s claims as to both the LDOC and the individual officers. Landor appealed, but only regarding the claim against the officers. The Fifth Circuit affirmed, holding that RLUIPA did not allow suits against officers in their individual capacities. The United States Supreme Court granted certiorari.

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Holding and Reasoning (Gorsuch, J.)

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Dissent (Jackson, J.)

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