Case Preview: Landor v. Louisiana Dept. of Corrections | Landor's Lost Locks: When Prison Guards Clip Constitutional Claims

Landor v. Louisiana Department of Corrections | Case No. 23-1197 | Oral Argument Date: 11/10/25 | Docket Link: Here Question Presented: Whether an individual may sue a government official in his individual capacity for damages for violations of RLUIPA. Overview This 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 Roadmap Opening: 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 enforcement Background: 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 sentence The 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 sentence Statutory 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 same The 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 remedy Landor'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-shaving Louisiana'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 damages Constitutional 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 spending power • Parallel to other federal funding programs requiring individual compliance The Practical Impact Question • Damages as deterrent: Will personal liability improve religious accommodation? • Louisiana's policy change: Department amended grooming policy in response to lawsuit • Private enforcement supplement: Government cannot monitor all prison violations • Fifth Circuit precedent shows even clear legal rulings insufficient without enforcement mechanism Broader Religious Liberty Implications If Landor Wins: • Prisoners gain powerful enforcement tool for religious rights violations • Individual deterrent effect on prison officials nationwide • Consistency with Tanzin's RFRA interpretation • Enhanced protection for minority religious practices in institutional settings If Louisiana Wins: • Limits enforcement to institutional defendants only • Potential immunity shield for individual religious rights violations • Inconsistency between RFRA and RLUIPA despite identical language • Reduced deterrent effect on individual officer misconduct Looking Ahead to November 10th Oral Arguments • Justices' reaction to "sister statute" argument and Tanzin precedent • Questions about Spending Clause limits on individual officer liability • Practical enforcement concerns and deterrent effects • Constitutional consistency between federal (RFRA) and state (RLUIPA) religious liberty protection Key Legal Concepts Explained Individual-capacity versus official-capacity lawsuits RLUIPA's Spending Clause and Commerce Clause foundations Religious accommodation in correctional settings • Statutory interpretation of identical language across related statutes • Personal liability as enforcement mechanism for constitutional rights