No. 23-1197October Term 2025Decided Jun 23, 2026
Damon Landor, Petitioner v. Louisiana Department of Corrections and Public Safety, et al.
The Supreme Court said RLUIPA allows money-damages claims against individual state officials.
Case status
- Current stage
- Decided
- Latest event
- Decision released Jun 23, 2026
- What it's about
An inmate sues individual prison officials over forced head-shaving that violated his Rastafarian religious practices. The case tests the scope of the Religious Land Use and Institutionalized Persons Act (RLUIPA) and whether inmates can sue individual officials for monetary damages.
Question presented
Whether RLUIPA permits suits for monetary damages against state officials in their individual capacities.
- Case path
United States Court of Appeals for the Fifth Circuit / Decision released Jun 23, 2026
- Area
Religious Liberty
Briefing
What it's about
The case asked whether RLUIPA lets a person seek money damages from state officials sued personally. The Court said yes, in a case brought by an inmate who said forced head-shaving violated his Rastafarian religious practice.
Vote
Impact
This means prisoners bringing RLUIPA religious-exercise claims can seek money damages from individual state officials, not just challenge a policy in the abstract. For example, a prisoner who says officers forced him to shave against his faith can pursue damages from those officials personally.
What's next
Lower courts now must apply this reading of RLUIPA in pending and future cases. Corrections agencies may review grooming and religious-accommodation policies and staff training because individual officers can face damages claims.
What did the Supreme Court rule in Landor?
The Court said RLUIPA lets a person sue a state official in an individual capacity for money damages. The case arose from forced head-shaving that conflicted with Rastafarian practice.
Who is affected by Landor's result?
Prisoners bringing RLUIPA claims can now seek money damages from individual state officials. Prison staff and agencies may need new training on religious-accommodation rules.
What happens next in Landor?
Lower courts must apply the Supreme Court's reading of RLUIPA in pending and future cases. Prisons and corrections agencies may review grooming and religious-accommodation policies to reduce liability.
Decision
What the Court decided
The Supreme Court said RLUIPA allows money-damages claims against individual state officials.
- Result
- Affirmed
Impact
State prisoners and prison officers in systems receiving federal funds are directly affected. Prisoners can sue prison systems, but not officers personally for damages (money compensation) here. For example, Landor's forced head-shaving claim cannot continue against the officers personally. This may push future RLUIPA cases toward prison departments instead of individual-capacity suits (claims against officials personally). The Court said personal liability requires voluntary, knowing consent in an agreement with the federal government.
Not official Court text.
Timing
Decided June 23, 2026
The Court released its decision 225 days after oral argument on November 10, 2025. The median for cases argued in November is 136 days.
Related cases




Grounding
- Grounding
- Primary materials plus reporting.
- Note
- Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
- Checked
- Aug 2, 2026
- Method
- Methodology
Primary materials10
Supreme Court docket 23-1197
docket | Aug 19, 2026
Primary case document
Supreme Court document | Aug 19, 2026
Opinion of the Court - NG
opinion | Jun 23, 2026
Questions Presented
brief | Mar 8, 2026
Oral Arguments - Landor
audio | Nov 10, 2025
Petition
brief | May 3, 2024
SupremeCourt.gov
official | Aug 2, 2026
SupremeCourt.gov
official | Aug 2, 2026
SupremeCourt.gov
official | Aug 2, 2026
SupremeCourt.gov
official | Aug 2, 2026