Landor v. Louisiana Dept. of Corrections

June 12, 2024

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.

RFI’s position: To hold that damages suits against officials in their individual capacity are unavailable under RLUIPA conflicts with the Supreme Court’s decisions, in particular with Tanzin v. Tanvir.

Read the amicus brief here.