Case Preview: Landor v. Louisiana Dept. of Corrections | Landor's Lost Locks: When Prison Guards Clip Constitutional Claims
Case Preview: Landor v. Louisiana Dept. of Corrections | Landor's Lost Locks: When Prison Guards Clip Constitutional Claims  
Podcast: SCOTUS Oral Arguments and Opinions
Published On: Sat Nov 01 2025
Description: Landor v. Louisiana Department of Corrections | Case No. 23-1197 | Oral Argument Date: 11/10/25 | Docket Link: HereQuestion Presented: Whether an individual may sue a government official in his individual capacity for damages for violations of RLUIPA.OverviewThis episode examines Landor v. Louisiana Department of Corrections, a case that could reshape religious liberty enforcement in prisons by determining whether inmates can sue individual prison officials for personal damages under RLUIPA. The case centers on Damon Landor, a devout Rastafarian whose decades-long dreadlocks were forcibly shaved despite existing Fifth Circuit precedent protecting such religious practices.Episode RoadmapOpening: Religious Freedom Behind Bars• November 10th, 2025 oral argument date• Stakes: Personal liability for prison officials violating religious rights• Case follows Supreme Court's 2020 Tanzin decision allowing individual damages under sister statute RFRA• Potential nationwide impact on prisoners' religious rights enforcementBackground: The Nazarite Vow Violation• Damon Landor: devout Rastafarian following biblical Nazarite Vow for nearly two decades• Dreadlocks fell "nearly to his knees" when incarcerated in August 2020• First four months uneventful at two accommodating facilities• Transfer to Raymond Laborde Correctional Center with three weeks left in sentenceThe Shocking Violation• Landor provided intake guard with Ware decision requiring accommodation• Guards threw legal materials in garbage and summoned warden• Warden demanded documentation from sentencing judge• When Landor couldn't immediately provide, officials handcuffed him to chair and shaved him bald• Prison then kept Landor in lockdown for remainder of sentenceStatutory Framework: RFRA and RLUIPA as "Sister Statutes"• Both enacted in response to Employment Division v. Smith limiting religious freedom protection• RLUIPA applies to state prisons receiving federal funds through Spending and Commerce Clauses• Identical language to RFRA: "appropriate relief against a government"• Tanzin held RFRA permits individual-capacity damages - question is whether RLUIPA does sameThe Circuit Split and Lower Court Decision• Fifth Circuit rejected individual-capacity claims under RLUIPA• Distinguished Tanzin as applying only to federal officials under RFRA• Judge Oldham's dissent called facts "stark and egregious"• Judge Clement's concurrence noted "visceral" need for damages remedyLandor's Arguments (Seeking Individual Damages)• RLUIPA's text is "identical" to RFRA's - same language must mean same remedies• Damages were available against state officers before Smith decision• RLUIPA "made clear" Congress intended to "reinstate" pre-Smith protections and remedies• Damages often "only form of relief that can remedy" violations like forced head-shavingLouisiana's Arguments (Opposing Individual Liability)• RLUIPA only permits suits against "government" entities, not individual officials• Sossamon precedent shows Congress did not clearly authorize damages against states• Spending Clause conditions cannot extend to individual officer liability• Sovereign immunity principles protect state officials from personal damagesConstitutional Stakes: Spending Clause Analysis• Whether Congress can impose personal liability conditions on state officials through federal funding• Landor argues conditions clearly relate to federal spending on prisons• Louisiana contends extending liability to individuals exceeds...