What Christians should know about the Supreme Court's 'Landor' ruling
The justices voted 6–3 against a Rastafarian prisoner claiming religious discrimination. An expert explains how this ruling may affect Christians.
!Image 1: The U.S. Supreme Court is seen at sunset on June 6, 2026 in Washington, DC.
The U.S. Supreme Court is seen at sunset on June 6, 2026 in Washington, DC.
The US Supreme Court ended its run of favorable religious freedom decisions today, ruling against a prisoner who had faced discrimination from state officials on account of his beliefs. The decision is narrow and speaks to a more technical question than the details may suggest, but the outcome is discouraging for those seeking more robust religious expression protections under the First Amendment, regardless of whom they protect.
The case, _Landor v. Louisiana Department of Corrections and Public Safety_, originated in 2020. During his five-month imprisonment, Damon Landor had been allowed to maintain a head of long hair consistent with his Rastafarian beliefs. Following a transfer to another facility, officials sought to cut Landor’s hair per prison protocol. Landor objected and produced evidence of past accommodations, as well as a federal court decision supporting claims like his. Despite this evidence, the prison’s warden ordered Landor’s head shaved.
Landor later sued both the prison system and the warden, seeking monetary damages from the warden personally for violating his constitutional rights. At the heart of Landor’s lawsuit was the Religious Land Use and Institutionalized Persons Act (RLUIPA), a 2000 statute enshrining certain protections for religious freedom into federal law. Lower courts dismissed Landor’s claims, determining past precedent shields state officials from personal financial penalties.
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During oral arguments in November, a clear majority of Supreme Court justices seemed skeptical of Landor’s position. At the heart of their uncertainty was a debate over when and how government officials can be held personally liable for their professional conduct. Specifically, the justices wonder whether RLUIPA even allows lawsuits against state officials for violating people’s religious freedom rights.
In its 6–3 decision, split along ideological lines, the court ruled against Landor. Writing for the majority, Justice Neil Gorsuch said that while RLUIPA opened prison _systems_ to lawsuits for violating inmates’ First Amendment rights, the law did not expose prison _officials_ to liability for their role in said violations. In this way, the case is less about religious freedom and more about who can be held legally responsible for violations of federal law. “Because [prison officials] never agreed to answer suits like this one,” Gorsuch wrote, “Mr. Landor’s case cannot proceed against them.”
The court’s three liberal justices disagreed, with Justice Ketanji Brown Jackson writing a dissenting opinion. “It is not often,” she wrote, “that a real-life incident so clearly illustrates Congress’s reasons for adopting legislation, or the Constitution’s wisdom in enabling it.” She argued that RLUIPA’s whole purpose is to provide a remedy for people whose constitutional rights had been violated. As a result of the court’s decision, she lamented, “encroachments on prisoners’ statutory rights are likely to happen with fair frequency, as state-empowered prison officials will have little incentive to abide by federal law.”
Prior to this case, the Supreme Court issued several favorable decisions under RLUIPA. In _Cutter v. Wilkinson_, the court unanimously ruled that RLUIPA did not violate the First Amendment’s establishment clause and therefore several inmates should be given reasonable accommodations for their religious requests. In _Holt v. Hobbs_, the court unanimously ruled for an inmate’s request to maintain a short beard in accordance with his Muslim beliefs. And in _Ramirez v. Collier_, the court ruled 8–1 that a prisoner’s spiritual adviser could be present at his execution.
This case is different. The court did not strengthen or limit RLUIPA per se but rather held that the law does not provide an avenue for litigants to claim monetary damages from individuals who violate their constitutional rights. In this way, _Landor_ is not a substantive decision but a technical one. The court can be sympathetic to Landor’s claims while simultaneously finding that he has no recourse under RLUIPA as currently written.
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Still, we as Christians should be concerned with the outcome in _Landor_ for at least two reasons.
First, our government is constituted by human beings, each of whom is made in God’s image _and_ affected by the Fall. In this case, Landor argued prison officials should be accountable for violating his constitutional rights despite clear reasons they shouldn’t have done so. And while the Supreme Court ultimately disagreed, it does not change the fact that people in positions of power should be scrutinized precisely because of their proximity to power. Wanting to hold government officials accountable for their actions is consistent with the Christian understanding of sin.
Second and just as important, stronger First Amendment protections for religious freedom benefit everybody, regardless of the details in individual cases. Supreme Court decisions tend not to distinguish between views or beliefs, and the precedents they establish generally apply regardless of sect or tradition. We may believe religious minorities like Landor are mistaken about life’s biggest questions, but a free exercise victory for one benefits the free exercise rights of all.
Daniel Bennett is professor of political science at John Brown University. He has written two books,_Defending Faith: The Politics of the Christian Conservative Legal Movement_ and _Uneasy Citizenship: Embracing the Tension in Faith and Politics_.