Landor v. Louisiana Department of Corrections and Public Safety

    Issues

    Are monetary damages permissible against a government official for violations of the Religious Land Use and Institutionalized Persons Act of 2000?

    Oral argument:
    November 10, 2025
    Court below:
    United States Court of Appeals for the Fifth Circuit

     

    This case asks the Supreme Court to consider whether a violation of the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA) by a government official allows for an individual to seek monetary damages against that official in their individual capacity. Landor contends that RLUIPA should be interpreted identically to the Religious Freedom Restoration Act of 1993 (RFRA), which allows for individual-capacity monetary damages against a government official. Landor also argues that the Spending Clause of the United States Constitution permits RLUIPA to allow for these damages. The Louisiana Department of Corrections and Public Safety argues that RLUIPA is distinct from RFRA precisely because the Spending Clause of the Constitution precludes individual liability of state officials, so RFRA and RLUIPA should not be interpreted identically. This case directly impacts freedom of religion rights in prisons, specifically for religious minorities, and the deterrence of future violations of those rights.

    Questions as Framed for the Court by the Parties

    Are monetary damages permissible against a government official for violations of the Religious Land Use and Institutionalized Persons Act of 2000?

    Facts

    Incarcerated in 2020 for approximately six months, Damon Landor was held in three different correctional facilities in Louisiana.  Landor, who was forty years old at the time of his conviction, was living in Slidell, Louisiana, when police arrested him for drug possession.  Landor practiced Rastafarianism and, in accordance with Rastafarianism, adhered to the Nazarite Vow, which is kept by growing one’s hair without cutting it.  Thus, Landor grew his dreadlocks for nearly twenty years. The first two correctional institutions that housed Landor permitted him to continue growing his hair without incident. The second correctional facility voluntarily altered its existing hair policies to ensure Landor could keep his dreadlocks without issue.

    With three weeks remaining in his sentence, Landor was transferred to Raymond Laborde Correctional Center. Immediately upon arrival, Landor provided a guard with proof of his prior religious accommodations along with a copy of the decision in Ware v. Louisiana Department of Corrections. In Ware, the United States Court of Appeals for the Fifth Circuit found that involuntarily cutting Rastafarians’ hair violated the Religious Land Use and Institutionalized Persons Act (RLUIPA), a law protecting prisoners’ religious practices. The guard discarded this information and contacted the prison’s warden, Marcus Myers. Warden Myers arrived and demanded specific documents from the judge who initially sentenced Landor that corroborated Landor’s Rastafarian beliefs. Landor was unable to meet that demand on-the-spot. Guards then moved Landor to a different room, handcuffed him, and shaved his dreadlocks off entirely.  

    Landor sued the Louisiana Department of Corrections and Public Safety, the correctional facility, Warden Myers, and the secretary of the department, James LeBlanc, in both their official and individual capacities. Landor filed suit under the RLUIPA and 42 U.S.C. § 1983, which creates a cause of action against state government employees who deprive a plaintiff of their constitutional rights. The United States District Court for the Middle District of Louisiana dismissed the suit, agreeing with Myers and LeBlanc that the suits against them in their individual capacities were moot because RLUIPA bars a private right of action for the damages requested.

    On appeal, the Fifth Circuit affirmed that decision. In Sossamon v. Texas, a decision affirmed by the U.S. Supreme Court, the Fifth Circuit held that RLUIPA bars lawsuits against prison officials in their individual capacities. The court additionally rejected the idea that other precedent allowing money damages against an official in their individual capacity under the similar Religious Freedom Restoration Act (RFRA) should overcome Sossamon because the cases involved different laws without enough similarities to require identical rulings.

    Landor then appealed to the United States Supreme Court who granted certiorari on June 23, 2025. 

    Analysis

    INTERPRETING SIMILAR LANGUAGE ACROSS TWO STATUTES

    Landor first argues that both the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA) and the Religious Freedom Restoration Act of 1993 (RFRA) should be interpreted identically, which would allow individual-capacity damages for lawsuits brought under RLUIPA. Landor points out that RLUIPA and RFRA contain identical text in multiple places, and the Court has previously interpreted RLUIPA in the same manner as RFRA by relying on cases in which it interpreted RFRA to make RLUIPA decisions. Landor argues that because both RLUIPA and RFRA seek to vindicate the freedom of religion rights of citizens, the statutes have similar purposes. Landor notes that the Court has indicated that when courts face statutes with identical language and similar aims, courts should interpret that similar text to have the same meaning. Landor cites to Tanzin v. Tanvir, where the Court allowed individual-capacity damages against government officials for suits brought under RFRA, to highlight that not only is interpreting RFRA and RLUIPA identically appropriate, but also Tanzin is directly on-point to indicate that suits against government officials in their individual capacity should be allowed under RLUIPA. Particularly, Landor notes that the language in RLUIPA related to remedies, which allow individuals to seek “appropriate relief,” is identical to RFRA’s language. Thus, where the Court in Tanzin interpreted that language in RFRA to enable individual-capacity damages against government officials, the Court should rule on RLUIPA in the same way.

    The Louisiana Department of Corrections and other respondents (“Louisiana”) counter by distinguishing RLUIPA and RFRA based on RLUIPA’s reliance and origins in the Spending Clause.  Louisiana acknowledges that the Court in Tanzin found that RFRA enabled individual-capacity damages, but Louisiana argues that the Court’s holding is unimportant here. Unlike RFRA, Louisiana asserts that RLUIPA binds states through the Spending Clause of the United States Constitution, barring individual-capacity damages. Louisiana adds that the term “appropriate relief,” while similar to the language of RFRA, “is inherently context dependent.” Louisiana points to Sossamon v. Texas, where the Court held that relief under RLUIPA for the United States was limited to equitable relief in the form of injunctions and declaratory judgments, and not monetary damages, to similarly support barring individual-capacity damages against government officials under RLUIPA. Louisiana additionally points out that the Court’s ruling under Tanzin relied on a method of damages that had coexisted with the constitutional system for years, whereas RLUIPA’s reliance on the Spending Clause negates that longstanding constitutional synchrony. Louisiana contends that, despite similarities in RLUIPA and RFRA, reading RLUIPA without the distinct context of its Spending Clause origin is misguided.  

    THE SPENDING CLAUSE AND THE DIRECT SPENDING RULE

    The Spending Clause’s “direct spending rule” once followed the theory that only the agency being granted funds, rather than its employees, could be liable for a violation of the statute granting that funding; however, Landor argues that Court precedent proves that Congress may impose personal liability on employees or agents of a grantee government. Landor points to Salinas v. United States where the Court allowed for criminal liability of a state official who worked for a county jail that received federal funds, which Landor contends is in direct contradiction to the “direct spending rule,” along with other precedent involving Spending Clause liability for contractors and even members of the public to enforce this idea. Landor also emphasizes that the Court has cautioned not to overextend the analogy between the direct spending rule and treating Spending Clause legislation as a contract. Landor further contends that the employees and officers of the state should not be viewed as third parties for RLUIPA purposes because the only way for the state to comply with RLUIPA’s requirement here is for the officers and employees to comply while carrying out their jobs. In other words, Landor contends the state should be viewed as one-in-the-same as the officers and employees for RLUIPA purposes in this case because without their compliance, the state itself has no mechanism by which it can comply with RLUIPA.

    Louisiana counters by pointing to the Court’s recent opinion in Cummings v. Premier Rehab Keller, which allowed damages as a remedy in a suit that implicated the spending power only against the direct recipient of the federal funding. Louisiana contends that only the recipient of federal funds who consented to receiving those funds, and not the individual employees who are only third parties to the contract, can be held liable for money damages. Louisiana reinforces this argument with several lower court opinions supporting the view that only recipients of federal funds may be subjected to monetary damages should that contract be violated. Therefore, Louisiana asserts that only the State of Louisiana, by accepting federal funds, has opened itself to liability under RLUIPA. Louisiana also highlights a variety of lower court decisions that find RLUIPA distinct from the statute at issue in Salinas, where the Court found criminal liability even though the spending power would pose a barrier to monetary damages. Thus, criminal liability, according to Louisiana, is inapplicable to this case and bears no weight on individual capacity claims here.

    THE NECESSARY AND PROPER CLAUSE AND INDIVIDUAL-CAPACITY DAMAGES

    Landor argues that individual-capacity damages against government officials under RLUIPA are broadly constitutional beyond just their permittance by the Spending Clause. Landor notes Louisiana fails to dispute that state officials can be enjoined in their official capacities under RLUIPA, which can carry criminal contempt charges and fines, if a state official defied that injunction, thus already exposing state officials to money damages through the criminal system. Landor also notes that Louisiana does not contest that under South Dakota v. Dole, RLUIPA substantively satisfies the constitutional requirements under which Congress can impose conditions on states for accepting federal funds. Therefore, RLUIPA’s remedies also satisfy the constitutional standard under Dole. Landor then points to the Necessary and Proper Clause of the United States Constitution to argue that individual-capacity damages under RLUIPA are available. Landor contends that, under the Necessary and Proper Clause, Congress is free to authorize individual-capacity damages under RLUIPA, which are required and essential to enforcing the substantive provisions of RLUIPA. Because these suits are often filed after the harm has already occurred, Landor asserts that damages are often the only way for plaintiffs to seek redress for violations of their substantive free exercise rights under RLUIPA. Thus, Landor argues that individual-capacity damages are constitutional under the Necessary and Proper Clause.

    Louisiana counters Landor’s additional arguments for constitutionality, first by clarifying that Landor’s application of Dole is misplaced. According to Louisiana, Landor confuses placing the responsibility on the state via federal funding to find certain individuals guilty of breaking a law with being able to hold those state employees liable when failing to enforce said law. Louisiana argues that placing requirements on the state to condition receiving federal funds does not mean state actors can be held liable. Louisiana pushes back on Landor’s Necessary and Proper Clause argument by noting that the clause works to support the spending power rather than limit it. Louisiana argues that the Court’s decision in Sabri v. United States demonstrates that the Necessary and Proper Clause does not empower Congress to use any enforcement mechanism it sees fit, including the spending power. Louisiana also points to National Federation of Independent Business v. Sebelius, noting that the Court held the Necessary and Proper Clause cannot be used to increase federal power over the sovereign states. Louisiana additionally argues this reading of the Necessary and Proper Clause would enable Congress to enforce its own definition of various criminal laws that are otherwise reserved for state legislatures to define.

    Discussion

    DETERRENCE AND ACCOUNTABILITY

    Eleven former corrections officials, in support of Landor, (“Corrections Officials”), including the former heads of the Corrections Departments of Massachusetts, Pennsylvania, and Kansas, highlight how abuses against religious inmates have become commonplace throughout the United States.   The Corrections Officials contend that inmates have difficulty seeking redress for violations of their religious freedoms because the criminal justice system often transfers them to different facilities or releases them before they can seek injunctive relief, which moots their cases. Ensuring prisoners can obtain money damages when their rights are violated by prison staff, according to the Corrections Officials, would lessen the “inequity of religious freedom” that prisoners face. Religious organization Agudath Israel of America, in support of Landor, warns that, without allowing prisoners to collect money damages for violations of their free exercise of religion rights, the concept of religious freedom behind bars may become practically null-and-void.  

    The National Sheriffs’ Association (“NSA”) counters, in support of Louisiana, that the federal government intended RLUIPA to help enable inmates facing lengthy prison sentences to practice their faiths over time rather than punish corrections officials for singular instances in which an official infringes upon a prisoner’s religious practice.  Since the typical inmate’s local jail stay lasts only thirty-two days, the NSA maintains that allowing inmates to collect money damages from state and local corrections officials for mere “momentary disruptions” in religious affairs would disrespect the true purpose of RLUIPA and fail to generate any meaningful culture of accountability in corrections institutions. Additionally, the NSA highlights that, even without money damages from individual officials under RLUIPA, inmates who experience disruptions in their religious practices could still seek redress by pursuing claims under 42 U.S.C. § 1983.

    RESPECTING MINORITY RELIGIOUS BELIEFS

    Describing the tenets of their faith, Rastafari Scholars, in support of Landor, explain that far from being an ancillary element of their religion, growing dreadlocks “are…the physical embodiment of…the covenant of Jah [the Rastafari deity],” and the prison officials who cut Landor’s hair “uncrowned him before God.”  The Rastafari Scholars explain that they are not alone in these deep spiritual ties to their hair, as India’s Sadhus and East Africa’s Galla communities also consider hair a symbol of divine connection. Thus, several faiths’ practices could be in jeopardy without judicial intervention and action against those violating such vital tenants of religion. An interfaith alliance of Christian, Muslim, Jewish, and Sikh leaders (“Interfaith Alliance”), in support of Landor, furthers the idea that prison officials routinely mistreat religious minorities because officials have never been accountable for failing to understand uncommon faith traditions.  As practitioners of religions ranging from Orthodox Judaism to Hinduism and Sikhism have been denied basic religious accommodations in recent years, the Interfaith Alliance contends that hostility toward minority religions will continue if the judiciary does not hold prison officials personally accountable for their conduct.

    The NSA, in support of Louisiana, highlights that corrections officials are resource-limited and often house inmates on a very short-term basis, leading to busy schedules that may make it difficult to accommodate every single prisoner’s religious requests. RLUIPA, the NSA contends, intends to rectify long-standing impediments to prisoners’ religious practices without trying to attack prison officials in their personal capacity for honest attempts to perform their job duties. Further, the NSA notes that “any alleged disruption” to an inmates’ religious practices “would be fleeting at best.” The NSA’s view echoes the long-standing national conversation surrounding the lack of support for stressful law enforcement jobs, including correctional officer positions. While state corrections departments may not be perfect in ensuring religious freedom to every inmate, empirical research suggests that they are highly productive under conditions unfathomable to most Americans and should not be made personally liable for relatively minor missteps.

    Conclusion

    Authors

    Written by:    Andrew R. Davis and Cameron T. Hines

    Edited by:      Sierra Berry

    Additional Resources