Landor v. Louisiana Dept. of Corrections

September 12, 2025

Summary of facts: State prison guards handcuffed a Rastafarian prisoner and held him down while shaving his lifelong growth of hair, in violation of a court order to leave the inmate alone. The inmate sued for damages under the Religious Land Use and Institutionalized Persons Act (RLUIPA). The U.S. Court of Appeals for the Fifth Circuit condemned the guards’ act but followed a circuit precedent that damages are not available under RLUIPA. The inmate has asked the Supreme Court to review the case, arguing that the Fifth Circuit should be overruled in light of Tanzin v. Tanvir, in which the Court held that RLUIPA’s sister statute, the Religious Freedom Restoration Act (RFRA), authorizes damages. The Court agreed to hear the inmate’s case.

RFI’s position: RLUIPA provides that people incarcerated in state prisons that receive federal funding can bring a claim and “obtain appropriate relief against a government.” In Tanzin v. Tanvir, the Supreme Court unanimously held that individual-capacity damages are “appropriate relief” under RFRA. That conclusion requires the same result under RLUIPA, which uses the identical phrase (derived directly from RFRA).

Read the brief here.