Landmark suit may reshape personal financial exposure for frontline prison staff in religious rights cases.
When Damon Landor entered Louisiana’s Raymond Laborde Correctional Center in July 2020, he brought with him nearly floor-length dreadlocks grown in adherence to his Rastafarian faith, along with a copy of a 2017 Fifth Circuit ruling—Ware v. Louisiana Department of Corrections—protecting religious hair under the Religious Land Use and Institutionalized Persons Act (RLUIPA).
According to Landor, prison officials took the court decision he handed them, threw it in the trash, and forcibly shaved his head. He sued under RLUIPA, seeking monetary damages from the guards and administrators involved. The Fifth Circuit called the conduct “egregious” but ruled that RLUIPA does not allow damages from individuals—only from the government, which itself may be immune.
The Supreme Court granted review in Landor v. Louisiana Department of Corrections (No. 23-1197) on June 21, 2025. The justices will decide whether RLUIPA permits personal-capacity lawsuits against individual government officials, a question that has split federal appeals courts.
Personal-capacity suits target officials as individuals, not as representatives of the state. Unlike official-capacity claims, where the government entity pays, personal suits impose financial liability directly on the employee. But because states often invoke sovereign immunity to avoid damages, prisoners frequently name line officers to keep claims alive.
Landor relies on the Court’s 2020 decision in Tanzin v. Tanvir, which allowed damages against federal officials under the similarly worded Religious Freedom Restoration Act (RFRA). He argues that RLUIPA’s nearly identical language—authorizing “appropriate relief against a government”—must be read the same way.
Louisiana disagrees, arguing that RLUIPA is Spending Clause legislation, operating like a contract between the federal government and the state. Since only the state accepted the funds, only the state—not its employees—should bear any potential liability. Guards, Louisiana argues, never consented to personal risk.
From a public policy standpoint, this diverges from private-sector norms. If a grocery store worker negligently violates a policy, it’s the employer—not the worker—who is liable. But sovereign immunity lets states avoid responsibility for the same misconduct, leaving lower-level workers as the only available defendants.
The consequences for prison staff could be far-reaching. Even meritless suits can lead to thousands in legal costs. Corrections officers—often modestly paid—could see their personal finances devastated by lawsuits brought by litigious inmates. Over time, the stress of the mere threat of lawsuits brought by inmates, who often represent themselves, could alter the balance of power inside prisons and deter people from entering or staying in an already difficult profession.
Every circuit to reach the question has concluded that RLUIPA does not allow personal-capacity damages claims. By taking Landor v. Louisiana, the justices are being asked to break, not harmonize, that consensus. The case is expected to be argued sometime in the 2025-26 Term, with a decision likely by June 2026, though the Court has not yet set a formal date.
Oral argument will be scheduled for the 2025–26 term. A decision is expected by June 2026.
Supreme Court Documents: https://www.supremecourt.gov/search.aspx?filename=/docket/docketfiles/html/public/23-1197.html