Supreme Court
RECENT RULINGS
ON THE DOCKET
Alignment is each justice's general judicial philosophy as commonly described, not a party. Justices don't belong to parties, and they don't always vote with their bloc.
Alignment is each justice's general judicial philosophy as commonly described, not a party. Justices don't belong to parties, and they don't always vote with their bloc.
No. 23-1197 · October Term 2025
May an individual sue a government official in his individual capacity for damages for violations of the Religious Land Use and Institutionalized Persons Act (RLUIPA)?
Damon Landor, a devout Rastafarian, vowed as part of his faith never to cut his hair—a religious commitment known as the Nazarite Vow. Incarcerated in 2020, Landor was first held at the St. Tammany Parish Detention Center and later at LaSalle Correctional Center, both of which allowed him to maintain his hairstyle in accordance with his religious beliefs. After approximately five months and with three weeks left in his sentence, Landor was transferred to Raymond Laborde Correctional Center. Upon arrival, Landor proactively explained his religious practices and presented documentation of previous accommodations, including a copy of a federal court decision supporting similar claims. An intake guard disregarded his documentation, summoned the warden, and upon Landor’s inability to produce immediate additional proof of his beliefs, guards forcibly handcuffed Landor and shaved his head. Following his release, Landor sued the Louisiana Department of Corrections and Public Safety, its Secretary James LeBlanc, the correctional center, and Warden Marcus Myers, asserting claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA) and 42 U.S.C. § 1983 for violations of…
From Oyez.
State employees may not be held liable in their personal capacities under a Spending Clause statute such as the Religious Land Use and Institutionalized Persons Act of 2000 unless those individuals have voluntarily and knowingly consented to answer private suits under the statute; the individual defendants in this case did not do so here, so Landor’s case cannot proceed against them.
Majority: Neil M. Gorsuch, John G. Roberts, Clarence Thomas, Samuel A. Alito, Brett M. Kavanaugh, Amy Coney Barrett
Dissent: Ketanji Brown Jackson, Sonia Sotomayor, Elena Kagan