Supreme Court Rules Inmates Cannot Sue Prison Guards for Religious Rights Violations
In a 6-3 decision, the Supreme Court ruled Tuesday that prison inmates cannot sue individual guards or wardens for damages when religious rights are violated. While the Religious Land Use and Institutionalized Persons Act allows suits against state prison systems, Justice Neil M. Gorsuch stated the law does not authorize private lawsuits against employees.
Why can’t inmates sue individual prison employees?
According to Justice Neil M. Gorsuch, the federal government requires states to follow the law when receiving money for prisons, education, and healthcare. Gorsuch wrote that this funding requirement does not authorize private lawsuits against employees.
The majority of the court found that Congress lacks the regulatory authority to impose liability on officers directly. Gorsuch noted that this reasoning confirms the Court of Appeals was correct in tossing out the specific suit in question.
What happened in the case of Damon Landor?
Damon Landor, a devout Rastafarian in Louisiana, had grown dreadlocks for nearly two decades. With three weeks remaining in a five-month prison term, Landor was transferred to another facility.
Landor carried a federal appeals court opinion stating that Rastafarian inmates have a protected religious right to wear dreadlocks. According to the source, guards threw that document in the trash.
The warden then ordered guards to handcuff Landor to a chair and shave his head. Landor later sued the warden and guards under RLUIPA, which promised “appropriate relief” to those whose rights were violated.
How did the court and advocates react?
Justice Ketanji Brown Jackson, joined by Justices Sonia Sotomayor and Elena Kagan, dissented. Jackson wrote that the decision transforms a federal statute into an invitation to be accepted or declined, leaving prisoners remediless even when violations are blatant.
Rachel Rossi, president of the Alliance for Justice, stated the ruling will further erode critical civil rights protections for incarcerated people. Rossi argued that if there is no remedy for such a transgression, there is no justice.
Rachel Laser, chief executive of Americans United for Separation of Church and State, said the decision endangers the religious freedom of vulnerable incarcerated people. Laser claimed the court allows the government to trample the religious freedom of non-Christians.
What may happen next for incarcerated people?
Incarcerated individuals who suffer religious violations may be limited to filing suits against state prison systems rather than individual staff members. This could result in fewer direct accountability measures for guards and wardens.
Legal challenges may shift toward targeting state entities if private lawsuits against employees remain prohibited. Future litigation could focus on whether state systems provide sufficient “appropriate relief” under RLUIPA.
Frequently Asked Questions
- What is RLUIPA? It is the Religious Land Use and Institutionalized Persons Act, adopted by Congress in 2000 to protect religious liberty.
- Who wrote the majority opinion for the Supreme Court? Justice Neil M. Gorsuch wrote the opinion for the six conservative justices.
- What was the specific violation in Damon Landor’s case? Guards threw away a legal opinion protecting his rights, and a warden ordered him handcuffed to a chair to have his head shaved.
How should the law balance state funding requirements with individual employee accountability?