On June 23, 2026, the U.S. Supreme Court issued its decision in Landor v. Louisiana Department of Corrections and Public Safety, addressing whether correctional employees can be held personally liable for damages under the Religious Land Use and Institutionalized Persons Act (RLUIPA).

 

The case involved a Louisiana inmate who alleged that correctional staff forcibly cut his hair despite being aware of his Rastafarian religious beliefs, which require adherents to leave their hair uncut. Interestingly, the inmate-filed suit under RLUIPA specifically seeking monetary damages from individual correctional officers in their personal capacities.

 

In a 6-3 majority opinion authored by Justice Neil Gorsuch, the Court held that individual correctional employees cannot be held personally liable under RLUIPA unless they have knowingly and voluntarily agreed to such liability. The Court reasoned that RLUIPA was enacted under Congress’s Spending Clause authority and functions as an agreement between the federal government and the state agency receiving federal funds—not individual employees. Because the officers themselves never consented to be sued under the statute, the inmate’s claims against them could not proceed.

 

The decision affirms a ruling by the Fifth Circuit Court of Appeals as well as other circuit courts who have ruled similarly and provides important clarification regarding the scope of liability under RLUIPA. While correctional agencies receiving federal funds remain subject to RLUIPA’s requirements protecting inmates’ religious exercise, the Court concluded that the statute does not create a federal cause of action for monetary damages against individual officers acting in their personal capacities.

The ruling is significant to correctional administrators, legal counsel, and line staff, as it further defines the legal framework governing religious accommodation claims within correctional facilities. For specifics on how this ruling coincides with religious rights of inmates, please refer to the NIJO Legal-Based Jail Guidelines P02.02.01 Inmates’ Constitutional Rights to Religion and P02.03.01 Inmates’ Rights to Religion under the Religious Land Use and Institutionalized Persons Act and DACOTA online training course (Religion 3: RLUIPA). It will also be extensively discussed at the JAILCON and ELITE Academy. If your agency would like more information about this or related training, please contact us.