The Supreme Court ruled 6-3 that prison guards cannot be sued personally for money damages under a federal religious freedom law — and Justice Neil Gorsuch wrote the opinion that shut down Justice Ketanji Brown Jackson’s dissent.
Story Snapshot
- Justice Gorsuch led a 6-3 majority ruling that individual prison officers cannot be held personally liable for money damages under the Religious Land Use and Institutionalized Persons Act (RLUIPA).
- The Court used contract law logic: just as you can’t sue someone for breaking a contract they never signed, you can’t sue officers under a law they never personally agreed to.
- Ten federal appeals courts had already ruled the same way before this case reached the Supreme Court.
- Justice Jackson’s dissent argued the ruling contradicts decades of precedent, but her side could not point to contracts or employment records showing officers were ever told they could be sued personally.
What the Landor Case Was About
Damon Landor, a Rastafarian prisoner in Louisiana, said prison guards forced him to cut his dreadlocks — a serious violation of his religious beliefs. He sued the guards personally for money damages under RLUIPA, the federal law that protects religious freedom in prisons. The Fifth Circuit Court of Appeals threw out his lawsuit. The Supreme Court agreed to hear the case to settle the question once and for all.
The Religious Land Use and Institutionalized Persons Act (RLUIPA) was passed by Congress using its Spending Clause power. That means it works like a contract: the federal government gives states money, and states agree to follow the law’s rules. Louisiana’s Department of Corrections accepted that deal. But the individual guards who worked there never personally signed anything agreeing to be sued for money damages under RLUIPA.
Why Gorsuch’s Majority Opinion Won
Justice Gorsuch wrote the majority opinion and kept the reasoning simple. A lawsuit for breaking a contract cannot go forward against someone who never signed the contract. The same logic applies here. The state agency agreed to RLUIPA’s terms when it took federal money — but individual officers did not. Because the officers never personally consented to face personal lawsuits, the case against them could not move forward. The ruling was 6-3, with the three liberal justices dissenting.
This was not a new idea. Ten federal appeals courts had already ruled that RLUIPA does not allow prisoners to sue individual prison officials for personal money damages. The Fifth Circuit had made this same call before, saying it was bound by earlier decisions even though the judges strongly condemned the treatment Landor received. The Supreme Court’s ruling simply confirmed what most courts had already decided.
Jackson’s Dissent and Why It Fell Short
Justice Jackson argued the majority’s consent rule has no clear basis in the Constitution’s text. She also pointed to the Religious Freedom Restoration Act (RFRA), a similar law, where courts have allowed personal-capacity lawsuits against government officials. If the same language in RFRA allows those suits, she argued, RLUIPA should too. It’s a fair legal debate — but it ran into a wall of practical evidence.
The dissent’s core problem is what it could not produce. Jackson’s side offered no employment contracts, no training records, and no funding agreements showing that individual guards were ever told they could be personally sued under RLUIPA. The majority’s argument rested on a simple fact: the officers never agreed to this liability. Without documents showing otherwise, the dissent was left arguing from legal theory rather than concrete evidence. That gap likely cost Jackson the majority.
What This Means Going Forward
The ruling does not strip RLUIPA of its teeth entirely. State prison systems that take federal money are still bound by the law. If they violate it, Congress can cut off their funding. Prisoners can still sue for injunctions — court orders that force officials to stop violating their rights. What they cannot do is sue individual guards personally for money. That distinction matters, but it does leave a real gap for inmates seeking financial accountability from specific officers.
Louisiana Attorney General Liz Murrill called the ruling a victory for the state. Some religious liberty groups worry that without personal financial stakes, officers have less reason to think twice before trampling inmates’ faith. Congress could fix this by writing clearer language into RLUIPA — spelling out exactly whether individual guards can be sued. Until then, the Court’s ruling stands, and Gorsuch’s contract-law logic holds the field.
Sources:
reason.com, en.wikipedia.org, becketfund.org, theusconstitution.org, wsj.com
