A must-read for law students, criminal justice reform advocates, and constitutional scholars
In a pivotal development for religious liberty and prisoner rights jurisprudence, the U.S. Supreme Court has agreed to hear a high-stakes case that will determine whether government officials can be held personally liable for violating an inmate’s religious freedom under the Religious Land Use and Institutionalized Persons Act (RLUIPA).
At the heart of this case is Damon Landor, a devout Rastafarian and former inmate in Louisiana, whose religious vow to never cut his hair was abruptly and forcibly broken by prison officials. Now, the justices will answer a constitutional question that could redefine the contours of individual liability under federal religious freedom laws.
📘 The Case: Landor v. Louisiana Department of Corrections
Background:
Damon Landor, who follows the Rastafarian faith, had taken a Nazarite vow—a deeply religious commitment to abstain from cutting his hair. For nearly two decades, Landor honored this vow, including during a five-month prison sentence in Louisiana.
But in 2020, just three weeks before his release, prison officials shaved his head. Despite his attempts to explain his religious beliefs and even handing over a Fifth Circuit decision ruling such hair-cutting policies unconstitutional, the guards allegedly dismissed his pleas—literally throwing the court ruling in the trash.
Landor sued under RLUIPA, targeting both the state and the prison officials in their official and individual capacities. While claims against the state and officials in their official capacities are commonly barred by sovereign immunity, Landor pursued monetary damages against the officials personally, alleging a direct and deliberate violation of his religious rights.
The Legal Dilemma:
The lower courts, including the Fifth Circuit, ruled against Landor, holding that RLUIPA does not allow personal-capacity lawsuits for damages. But this interpretation sparked controversy because it conflicts with how other federal religious liberty laws, such as RFRA, are applied.
🧑⚖️ SCOTUS Precedent: Why the Justices Are Stepping In
Landor petitioned the Supreme Court, and in a rare show of alignment, the federal government supported his request for review.
The Biden administration pointed to two significant decisions:
- Sossamon v. Texas (2011): States cannot be sued for damages under RLUIPA due to sovereign immunity.
- Tanzin v. Tanvir (2020): Under RFRA, money damages are available against individual federal officials in their personal capacity.
The government’s position, as argued by Solicitor General D. John Sauer, is clear: Taken together, these precedents imply that individual government officials should be held accountable when they personally violate someone’s federally protected religious rights—even in prison.
The Supreme Court deliberated the petition for two consecutive conferences before granting review, signaling the significance and potential nationwide impact of the case.
🧨 Why This Case Matters
A ruling in favor of Landor could dramatically expand civil remedies for religious liberty violations within prisons. If the Court rules that RLUIPA allows personal-capacity lawsuits for damages, it would:
- Empower inmates to pursue justice for egregious, intentional violations.
- Force prison officials and institutions to respect religious accommodations or face personal accountability.
- Align RLUIPA’s enforcement with RFRA, strengthening civil liberties across different federal statutes.
On the flip side, a ruling against Landor could cement legal immunity for individual officials, weakening religious freedom protections behind bars.
Oral arguments are expected this fall, with a decision likely to land by mid-2025.
⚖️ Other Notable Supreme Court Actions:
🚨 Richard Jordan Execution Case Rejected
On the same day, the Court declined to hear the appeal of Richard Jordan, a Vietnam veteran on death row in Mississippi for a 1976 kidnapping and murder.
Jordan, who suffers from PTSD, argued that his 1998 resentencing violated due process because he was not provided with an independent mental health expert, as required by Ake v. Oklahoma (1985) and McWilliams v. Dunn (2017).
Instead, he was evaluated by a state-employed psychiatrist, whose report was used by prosecutors. Despite the potential conflict with precedent, the Court denied review, allowing Jordan’s execution to proceed.
🎓 Student Loan Rule Challenge Back On
In Department of Education v. Career Colleges and Schools of Texas, the justices agreed to resume briefing in a high-profile case challenging a Biden-era rule that streamlined student loan forgiveness for borrowers whose schools engaged in fraud or closed unexpectedly.
After a pause in the case to allow for administrative review under the new administration, the Department of Education confirmed it would continue defending the regulation. The case is now back on track for argument, likely in the fall term.
💊 Pharma Patent Case: Views Requested
Lastly, the Court requested the views of the federal government in Hikma Pharmaceuticals v. Amarin Pharma, a patent dispute involving generic drug labeling. This type of case could have broad implications for FDA regulations and intellectual property enforcement in the pharmaceutical industry.
#SCOTUS #ReligiousFreedom #RLUIPA #PrisonRights #ConstitutionalLaw #LegalNews #DeathPenalty #PTSDJustice #StudentLoans #PharmaLaw #LawBlog #LawStudents #CivilLiberties
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