Prison Grooming Free Exercise Case Headed To Supreme Court

View from behind of officer escorting prisoner in black and white striped uniform towards a building — A prison grooming free exercise case comes to the country’s highest court next term [Image from Wikimedia Commons]

In its upcoming fall term, the US Supreme Court will consider the consequences of a breach of the constitutionally guaranteed right of free exercise of religion. Landor presents the high court with a prison grooming free exercise case to analyze. Prisons exert great control over their inmates’ lives, dictating what they can wear, where they sleep, and when they exercise. Giving up the right to make such decisions comes when inmates enter this regulated environment. But prisoners do not give up all rights. Their constitutional right of free exercise of religion may supersede the decision-making authority of prison officials. But what happens when that right is violated?

Background Of Prison Grooming Case

In 2020, Damon Landor received a five-month sentence in Louisiana in connection with a drug possession charge. During the first four months months behind bars, he was housed at two different correctional facilities. The officials at these two facilities allowed Landor, a practicing Rastafarian, to keep his dreadlocks long or under a rastacap. However, trouble arose upon Landor’s transfer to the Raymond Laborde Correctional Center in Cottonport, Louisiana to serve the last three weeks of his sentence.

Prison guards dealing with Landor objected to his knee-length dreadlocks . In fact, Landor had not cut his hair in almost two decades. The prisoner provided the guards with proof of his religious accommodations. Additionally, he gave them a copy of a federal circuit court’s 2017 ruling that Louisiana’s practice of cutting the hair of Rastafarians violated federal law, specifically the Religious Land Use and Institutionalized Persons Act (“RLUIPA”). Nevertheless, the warden ordered Landor’s dreadlocks cut. The guards threw Landor’s paperwork in the trash, handcuffed him to a chair, and shaved his head down to the scalp.

Singer against lighted orange and yellow background swinging his long dreadlocks which reach down his back — Long dreadlocks (like pictured here) on Landor were subject to prison grooming in violation of his right to free exercise of religion [Image from Wikimedia Commons]

Free Exercise of Landor’s Faith Entailed Grooming

As a Rastafarian, Landor took a Nazirite vow in which he pledged to “let the locks of his hair grow.” Both a religious and political movement, Rastafari started in the 1930s in Jamaica. Reggae music grew out of the Rastafarian movement with the faith spreading across the world during the 1970s via singer, songwriter, and Jamaican music icon Bob Marley.

Pink star on Hollywood Walk of Fame with words "Bob" Marley inside — Reggae star Bob Marley helped spread Rastafarianism in the 1970s [Image from Wikimedia Commons]

One of the Rastafarian religious principles is a balanced lifestyle which includes wearing dreadlocks, long, ropelike strands of knotted hair which remain uncombed. Many Rastafarians wear their dreadlocks in a rastacap, which is a large, round, crocheted or knitted cap roomy enough to contain them. Until shaved off at Raymonde Laborde Correctional Center, Landor had worn his dreadlocks either loose or under a rastacap while incarcerated and held a religious accommodation to do so.

Side view of older black male from the shoulders up wearing a rastacap — Dreadlocks under a rastacap are worn by Rastafarians in the free exercise of their religion [Image from Wikimedia Commons]

The Free Exercise Clause and Federal Law

The First Amendment of the US Constitution states Congress shall make no law prohibiting the free exercise of religion. The express language in this amendment makes it applicable to Congress. However, the US Supreme Court held in a 1940 case that the clause is enforceable against state and local governments as well. This applicability occurs via the Due Process Clause of the Fourteenth Amendment.

Federal legislation also expressly protects prisoners from violations of their right to free exercise of religion. RUIPA, passed unanimously by Congress in 2000, was intended to deter state and local prisons from placing arbitrary or unnecessary restrictions on religious practices. The Louisiana prison system thus came within the law’s purview.

View up the steps of the front of the US Supreme Court Building — The US Supreme Court will consider the Landor prison grooming free exercise case in its Fall Term [Image from Wikimedia Commons]

Court Action Arises From Prison Grooming Incident

Landor brought suit in federal court against the intake officers at Raymonde Laborde Correctional Center based on their cutting his dreadlocks. He sought money damages from the officers in their individual capacities for violating RLUIPA. Based on that law’s failure to provide for damages against individual state officials, the presiding judge dismissed the case.

On appeal by Landor, his lawyers argued that denying those wronged by RLUIPA violations the ability to seek damages failed to provide the meaningful protection of religious liberty the law intended. But, based on a controlling prior decision, the three-judge panel of the 5th Circuit Court of Appeal upheld the lower court’s decision. The appellate court did strongly condemn the prison officers’ treatment of Landor though.

Up To The US Supreme Court

Undeterred, Landor pursued his case by petitioning the US Supreme Court to hear it. Over thirty religious groups and the Justice Department backed this request. They believe monetary damages are often the only way to hold prison officials accountable for violating religious rights.

On June 23, the high court announced its acceptance of the case for its fall term which begins in October. After arguments are heard, the Supreme Court’s decision should come by the summer of 2026. Winning the prison grooming free exercise case remains Landor’s goal. In reality, the biggest win may be helping other prisoners avoid having their religious rights violated in the future.