Supreme Court: Inmate cannot sue prison guards for religious rights violation

The U.S. Supreme Court ruled in a 6-3 decision June 23 that a former inmate cannot sue prison guards in their personal capacities for allegedly violating his religious rights while he was in their custody.

In the decision, authored by Justice Neil Gorsuch, the court found that Damon Landor — a Rastafarian whose dreadlocks were shaved in violation of his religious practice — does not have legal standing to seek monetary damages from the Louisiana Department of Corrections officials responsible for the incident.

Every justice appointed by Republican presidents sided with the majority, and every justice appointed by Democratic presidents dissented from the majority in the decision in Landor v. Louisiana Department of Corrections.

Landor contended that when he was taken to prison, he provided the guards with a copy of the Fifth Circuit Court of Appeals decision in Ware v. Louisiana Department of Corrections, which found that in most circumstances, shaving the head of a Rastafarian violates the Religious Land Use and Institutionalized Persons Act.

Landor alleges the guards threw his copy of the decision in the garbage, took him to another room, handcuffed him, held him down, and shaved his head.

In its decision the Supreme Court determined that the law does not permit lawsuits against the individual guards for such violations.

According to the ruling, the authority of the religious liberty law derives from the U.S. Constitution’s spending clause. It states the federal spending power allows Congress to put conditions on the money allocated to entities, such as prisons, but that it cannot regulate the conduct of private individuals under this authority without their express consent, meaning the officials themselves are not liable for any damages.

“Adopting Mr. Landor’s proposed cause of action would allow Congress to evade the consent requirement inherent in its Spending Clause authority and regulate directly the conduct of countless nonconsenting individuals in spheres traditionally reserved to the States,” the ruling states.

“Such a result would be inconsistent with principles of state sovereignty and a federal government of limited and enumerated regulatory powers,” it adds.

Justice Ketanji Brown Jackson, in her dissent, disagreed with the majority’s interpretation of the spending clause, asserting that the ruling diminishes constitutional powers and “transforms a federal statute into an invitation to be accepted or declined, deemed binding only if each particular defendant has explicitly agreed to be penalized.”

“Prisoners like Landor who suffer violations of their religious freedom in state prisons — no matter how blatant — will often be left remediless,” Jackson wrote. “And encroachments on prisoners’ statutory rights are likely to happen with fair frequency, as state-empowered prison officials will have little incentive to abide by federal law, even if it is handed to them on a piece of paper.”

In another 6-3 decision, which was split along the same lines, the Supreme Court also ruled practitioners of the Chinese spiritual movement Falun Gong had no standing to sue Cisco Systems, Inc. in spite of allegations the company’s technology was used by the Chinese government to persecute them for their religious beliefs.

The decision in Cisco Systems, Inc. v. Doe found that the practitioners did not have standing to sue under the Alien Tort Statute. Because there was no standing, the court did not determine whether the company aided the persecution in any way, which it denies doing.