The U.S. Supreme Court today granted review in Landor v. Louisiana Department of Corrections, (Docket No. 23-1197, certiorari granted 6/23/2025) (Order List). At issue in the case is whether an action for damages lies under the Religious Land Use and Institutionalized Persons Act in a suit against a prison official in his personal capaciy. (Petition for Certiorari). Plaintiff, a Rastafarian, had his dreadlocks forcibly shaved by prison guards. The Supreme Court has previously held that a damage action under RFRA can be brought against federal prison personnel, but the U.S. 5th Circuit Court of Appeals held that it would violate the Spending Clause to recognize a similar remedy under RLUIPA, which is a statute based on Congress’ Spending Clause authority. (See prior related posting.) The SCOTUSblog case page has links to all the pleadings and amicus briefs in the case.
