Can You Sue a Prison for Violating Your Religious Rights?

You can still ask a court to make a prison stop violating your religious rights, but after the Supreme Court's June 23, 2026 decision in Landor v. Louisiana Department of Corrections and Public Safety, you generally cannot collect money damages from the state prison officials who violated them under the federal law written to protect prisoners' religious exercise. The Court ruled 6-3 that the Religious Land Use and Institutionalized Persons Act, known as RLUIPA, does not let a prisoner sue state officials in their individual capacity (meaning out of the officer's own pocket, rather than only in their official government role) for money damages. The ruling came too late to help Damon Landor, the Rastafarian prisoner whose case brought the question to the Court, and it changes what a damages lawsuit can accomplish for prisoners in state custody nationwide.

What Is RLUIPA and What Does It Protect?

The Religious Land Use and Institutionalized Persons Act of 2000, or RLUIPA, is a federal law that limits how much state and local prisons and jails can restrict a prisoner's religious exercise. Congress passed it after courts ruled that the First Amendment does not automatically excuse prisoners from generally applicable prison rules that happen to burden their religion. RLUIPA requires prisons that accept federal money to avoid placing a substantial burden on an inmate's religious exercise unless the prison has a compelling reason and uses the least restrictive way of achieving it.

In practice, prisoners raise RLUIPA claims most often over grooming and hair-length rules that conflict with religious vows, access to religiously required diets, group worship and access to chaplains or religious services, and the ability to hold religious items such as prayer texts or ceremonial objects. The Supreme Court itself relied on RLUIPA in Holt v. Hobbs, a 2015 case requiring a prison to accommodate an inmate's religiously motivated beard. Closer to Landor's own situation, the Fifth Circuit Court of Appeals, which covers Louisiana, had already ruled in 2017, in Ware v. Louisiana Department of Corrections, that RLUIPA generally bars Louisiana prisons from cutting a Rastafarian's hair.

RLUIPA is what lawyers call Spending Clause legislation. The Spending Clause is the part of the Constitution that lets Congress raise and spend money for the general welfare and attach conditions to money it hands out to states. Congress used that power to tell state prison systems that if they take federal money, they agree to answer lawsuits from prisoners who say the prison substantially burdened their religious exercise. Louisiana's prison system, like nearly every other state's, takes federal money and is bound by that condition.

What Did the Supreme Court Decide in Landor?

The Court held that RLUIPA does not let a prisoner sue individual prison officials, such as wardens and guards, in their personal capacity for money damages. Justice Neil Gorsuch wrote the majority opinion, joined by Chief Justice John Roberts and Justices Clarence Thomas, Samuel Alito, Brett Kavanaugh, and Amy Coney Barrett. Justice Ketanji Brown Jackson dissented, joined by Justices Sonia Sotomayor and Elena Kagan.

The majority's reasoning rests on how Spending Clause laws work. Because RLUIPA was passed under Congress's power to spend money rather than its power to directly regulate conduct, the Court treated it like a contract between the federal government and the state prison system. Louisiana's prison agency agreed, as a condition of taking federal money, to answer certain lawsuits under RLUIPA. But the individual officers who worked for that agency never personally signed onto any such agreement. As Justice Gorsuch wrote for the Court, "because they never agreed to answer suits like this one, Mr. Landor's case cannot proceed against them any more than a breach of contract action might proceed against a defendant who never formed a contract." Put plainly, the officers were never parties to the deal Louisiana struck with the federal government.

The Court rejected several arguments for why the officers should still be liable, including the idea that they were bound because they were the prison agency's employees, or because federal money eventually reached them as paychecks. Each of those theories, the Court said, would let Congress use its spending power to regulate almost anyone connected to a federally funded program, a result it found inconsistent with the limited, specific powers the Constitution gives Congress.

Justice Jackson's dissent argued the majority built its ruling on a "loose contract analogy" that earlier cases had used only as an interpretive aid, and warned that prisoners who suffer violations of their religious freedom in state prisons "will often be left remediless." The Court also left one question unanswered: it did not decide whether RLUIPA authorizes money damages at all in other contexts, ruling only on the narrower question of whether individual state officials can be sued personally.

What Happened to Damon Landor?

Damon Landor is a Rastafarian whose faith required him to leave his hair uncut, a practice tied to what is known as the Nazarite Vow. He had kept his hair growing for about two decades, and it reached his knees by the time of the events in this case. In 2020, Landor was sentenced in Louisiana state court and spent a few months in custody. At the first two facilities that housed him, officials accommodated his uncut hair without incident.

Near the end of his sentence, with three weeks left to serve, Landor was transferred to a third facility. Knowing that intake officers at unfamiliar facilities sometimes cut prisoners' hair under standard grooming policies, he brought a printed copy of the 2017 Ware ruling, which had already established that RLUIPA generally bars cutting a Rastafarian's hair in Louisiana prisons. Landor handed the ruling to the intake guard. As Justice Jackson's dissent recounts, quoting the Fifth Circuit's opinion in the case, the guard was "Unmoved" and "threw Landor's papers in the trash." The guard summoned the warden, who demanded documentation from Landor's sentencing judge corroborating his religious beliefs. "When Landor couldn't instantly meet that demand, two guards carried him into another room, handcuffed him to a chair, held him down, and shaved his head."

Landor sued after his release, seeking money damages under RLUIPA from the Louisiana Department of Corrections and Public Safety as well as individual prison officials. A federal district court dismissed his claims, in part because his release from prison had already made his request for a court order moot. Landor appealed only the dismissal of his damages claims against the individual officers. The Fifth Circuit ruled against him, and the Supreme Court took the case to decide whether RLUIPA permits that kind of individual-capacity damages suit against state officials. It does not.

What Legal Options Still Work After This Ruling?

The Landor decision closes one door. Several others remain open, though each comes with real limits.

RLUIPA still allows prisoners to sue prison officials in their official capacity, meaning as representatives of the prison system rather than as individuals, to obtain what courts call prospective relief. Prospective relief is a court order that stops an ongoing violation or prevents one from happening, rather than money for harm already done. If a prison is currently denying you a religious diet, blocking group worship, or threatening to cut your hair against your beliefs, RLUIPA still lets you ask a court to order the prison to stop. The Landor Court did not disturb that path. The officers' own brief acknowledged that they may still face injunctive relief in their official capacities for RLUIPA violations, and the majority repeated that concession without questioning it.

Prisoners can also sue under 42 U.S.C. Section 1983, the federal civil rights statute, for violations of their First Amendment right to free exercise of religion. Unlike RLUIPA claims against individual officers after Landor, Section 1983 claims for constitutional violations remain available against officials personally, including for money damages. The obstacle is qualified immunity, a legal defense that shields government officials from personal liability unless the prisoner can show the official violated a right that was already "clearly established" in prior court rulings at the time of the violation. Qualified immunity has proven to be a difficult hurdle in many prisoner civil rights cases, since courts often find no earlier case addressed facts close enough to the ones at hand.

Federal prisoners are in a different position. Landor addressed state prisoners under RLUIPA, a Spending Clause statute. Prisoners in federal custody are covered by a related law, the Religious Freedom Restoration Act, or RFRA, which does not depend on the Spending Clause. In Tanzin v. Tanvir, decided in 2020, the Supreme Court unanimously held that RFRA does allow individual-capacity damages suits against federal officers who violate a person's religious exercise. That ruling was not disturbed by Landor. If you are held in a federal facility rather than a state one, the damages option RLUIPA just closed for state prisoners may still be open to you under RFRA.

Some states allow their own damages claims against prison officials for misconduct, separate from federal law, and nothing in Landor prevents a state from creating or keeping that kind of remedy. In Landor's own case, the officers' attorneys told the Court that a state-law claim might be available to him in Louisiana state court. Whether a similar option exists where you are held depends entirely on your own state's laws and varies widely, so it is worth raising directly with a legal aid organization or civil-rights attorney familiar with your state.

The Landor majority also pointed out that Congress could have written RLUIPA differently to reach individual officers, for example by conditioning federal funding to a prison system on its officers signing their own agreements with the federal government to answer RLUIPA suits, or by conditioning that funding on the state adopting its own law making officers liable for RLUIPA violations. Congress remains free to amend RLUIPA along those lines if it wants to create a damages remedy against individual state officials. That takes an act of Congress, not a court ruling.

What Should You Do If a Prison Violates Your Religious Rights?

Because money damages against individual state officials are now largely unavailable, timing and documentation matter more than ever.

Write down what happened as soon as you can. Note dates, the names of the officers involved, and exactly what was said and done. Keep copies of anything you submit, including grievance forms and any responses you receive. If other prisoners saw what happened, note their names too.

File a grievance right away. The Prison Litigation Reform Act generally requires prisoners to exhaust the prison's internal grievance process before filing a federal lawsuit over prison conditions, under 42 U.S.C. Section 1997e(a). Exhaustion means completing every step of the prison's own complaint procedure, including any appeal it offers, before a court will hear your case. Skipping this step is one of the most common reasons prisoner lawsuits get dismissed before a judge ever reaches the merits. Follow your facility's grievance procedure exactly, and keep your own copies of everything you file.

Seek a court order early, while the violation is happening or clearly about to happen. Because the strongest remaining remedy for state prisoners is prospective relief, an order stopping an ongoing or imminent violation, timing is critical. Once a violation is over and you have been released, a court usually has nothing left to order, since there is no ongoing harm to stop. That is close to what happened in Landor's own case: his release from prison made his request for a court order moot, leaving him only with a damages claim that the Supreme Court has now cut off. If you are still in custody and a violation is ongoing or about to happen, get a request in front of a judge as soon as you can, rather than waiting until after the fact.

Reach out to a legal aid organization or a civil-rights attorney. Groups that focus on prisoners' rights and religious liberty can help sort out which claims are realistic given the law in your state, including whether your state offers its own damages remedy against prison officials.

This article explains general legal information about a recent Supreme Court decision. It is not legal advice for your specific situation, and prison law varies by state and by the details of what happened to you. The full opinion in Landor v. Louisiana Department of Corrections and Public Safety is available from the Supreme Court at supremecourt.gov.