The case of Landor v. La. Dep’t of Corr. & Pub. Safety, No. 23-1197, slip op. (U.S. June 23, 2026) sits at the intersection of federal funding law and religious liberty in prisons. At its core, the dispute concerns the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), a federal statute passed under Congress’s Spending Clause power. RLUIPA says that when states accept federal funds for prisons, they must not substantially burden an incarcerated person’s religious exercise unless the restriction is the least restrictive means of furthering a compelling governmental interest.
Damon Landor, a Rastafarian prisoner, alleges that prison officials violated his religious beliefs by forcibly shaving his head despite knowing that his faith required him to keep his hair uncut. According to Landor, when he was transferred to another prison near the end of his sentence, he provided the new officers with a copy of an order protecting his religious practice. He alleges that the officers disregarded the order, discarded it, and cut his hair anyway. For Landor, the violation was not simply a disagreement over prison policy; it involved the loss of a religious practice that he believed was central to his faith. He sued under RLUIPA, seeking relief against both the Louisiana Department of Corrections and the individual prison officers in their personal capacities.
The key legal question before the Supreme Court was whether RLUIPA’s Spending Clause framework allows prisoners to seek monetary damages from individual state officers who themselves were not parties to the federal funding “agreement.”
Religious Liberty, Federal Funding, and Lessons for HB4117
