Damon Landor, a Rastafarian serving a five-month sentence in a Louisiana state prison, has petitioned the U.S. Supreme Court to seek damages after his dreadlocks were cut by prison officials. This case highlights the broader issue of religious freedom in prisons and the applicability of the Religious Land Use and Institutionalized Persons Act (RLUIPA).
Background of the Case
- Incident Details: Landor, admitted to the Raymond Laborde Correctional Center in 2020, was informed that his dreadlocks, worn for religious reasons, would be cut to comply with the prison’s grooming policy. Despite presenting evidence of a 2017 ruling that prohibited the cutting of Rastafarian prisoners’ locks, Landor’s hair was cut while he was restrained.
- Legal Proceedings: Landor’s initial lawsuit seeking damages was dismissed by a district court in September 2022. An appeal was also rejected by the Fifth Circuit in September 2023. The appeals court upheld the precedent from a 2009 case (Sossamon I), which stated that RLUIPA does not provide for damages against prison officials.
Implications of the Case
- RLUIPA and Damages: The RLUIPA, enacted in 2000, aims to protect the religious rights of individuals in institutional settings but does not explicitly address the provision of damages for violations. Federal prisons are covered under the Religious Freedom Restoration Act (RFRA), which includes damages, but state prisons do not have the same provision.
- Advocacy and Support: Landor’s case is supported by 35 religious organizations, including groups like the Interfaith Center of New York, the Muslim Public Affairs Council, and the Sikh Coalition. These organizations argue that without the possibility of damages, RLUIPA’s protections are ineffective. They stress that the absence of damages may leave minority faiths vulnerable to abuse.
- Legal and Religious Perspectives: Legal experts and advocates, such as Zack Tripp and Stephanie H. Barclay, argue that including damages in RLUIPA cases would ensure better protection for religious practices in state prisons. The lack of familiarity with minority faiths among prison officials can lead to violations of religious rights, often out of ignorance rather than intent.
Key Figures and Statements
- Zack Tripp: Attorney for Landor, emphasizes that the lack of damages under RLUIPA fails to provide real protection and that extending the law to include damages would set a precedent for better safeguarding minority faiths.
- Stephanie H. Barclay: Director of Notre Dame University Law School’s Religious Liberty Initiative, highlights the importance of interfaith support in protecting religious rights and ensuring prison officials respect diverse beliefs.
- Holly Hollman: Associate executive director of the Baptist Joint Committee for Religious Liberty, points out that the vague term “appropriate relief” in RLUIPA could include damages, but its current interpretation limits effective enforcement.
Next Steps
The Supreme Court will decide whether to hear Landor’s case in the fall. The outcome could influence the interpretation of RLUIPA and impact how religious rights are protected for prisoners across the U.S.
FAQ
1. What is RLUIPA and what does it cover? The Religious Land Use and Institutionalized Persons Act (RLUIPA) is a federal law aimed at protecting the religious rights of individuals in institutions, such as prisons. It prohibits substantial burdens on religious exercise but does not explicitly provide for damages in state prison cases.
2. Why is the inclusion of damages important in RLUIPA cases? Including damages would provide a tangible remedy for violations of religious rights and ensure that prison officials are held accountable, thereby reinforcing the protection of minority faiths.
3. What support has Landor’s case received? Landor’s case has garnered support from 35 religious organizations and various legal experts, who argue that extending RLUIPA to include damages is crucial for protecting religious freedoms in state prisons.
4. What precedent is Landor’s case trying to set? Landor’s case aims to extend the “appropriate relief” under RLUIPA to include damages, aligning state prison protections with those available in federal prisons under RFRA.
5. How might this case impact religious rights in prisons? If successful, Landor’s case could lead to stronger protections for religious practices in state prisons and set a precedent for how RLUIPA is interpreted and enforced.
