The US Supreme Court has delivered a landmark ruling that will have significant implications for religious freedom in prisons across America - and, by extension, the UK. The court's 6-3 decision effectively shields prison officials from lawsuits over violations of inmates' religious rights, even when those officials act under colour of state authority.
The case involved Damon Landor, a Rastafarian who was forcibly shaved in 2020 while serving time in Louisiana's Raymond Laborde Correctional Center. Landor had specifically informed guards about his faith and presented a prior court ruling supporting his right to maintain his dreadlocks - but was still subjected to the indignity of having his 'crown' cut off.
The top court concluded that the Religious Land Use and Institutionalized Persons Act (RLUIPA), enacted in 2000, does not extend to allow for lawsuits against state employees in their personal capacities. Justice Neil Gorsuch, writing for the conservative majority, argued that Congress lacks direct regulatory authority to impose such liability under the Spending Clause - citing states' consent when accepting federal funding as insufficient to create personal liability.
This ruling stands in contrast to several recent Supreme Court decisions that have favoured claims of religious liberty. For instance, in 2020, the court ruled that the Religious Freedom Restoration Act (RFRA), a related statute from 1993, did permit individual damages suits against federal officials for religious liberty violations.
However, the Louisiana case drew a distinction between RLUIPA and RFRA - arguing that while states agree to comply with federal rules by accepting funding, this does not automatically create personal liability for individual prison employees. In her dissenting opinion, liberal Justice Ketanji Brown Jackson highlighted that the original purpose of RLUIPA was to protect prisoners' right to religious exercise, expressing concern that this ruling will leave vulnerable individuals without recourse.
The decision has sparked debate about the limits of federal power and state responsibility when it comes to protecting prisoners' rights. It also raises questions for the UK's own prison system, which must grapple with similar challenges in balancing individual freedoms with institutional authority.