Photo by Romina Farías on UnsplashThe Supreme Court’s October 2025 term sees another lineup of cases that will potentially reshape our country’s legal landscape.
One of those cases is Landor v. Louisiana Dept. of Corrections and Public Safety, which asks whether a federal law permits inmates to sue prison officials and guards in their personal capacities after they’ve violated an inmate’s rights. While the inmate at the center of this case, Damon Landor, is a Rastafarian, not an atheist or agnostic, this case demonstrates how white Christian supremacy negatively impacts anyone who fails to conform to the majority worldview, including religious (or nonreligious) minorities.
Some background: In 2020, Landor was sent to Raymon Laborde Correctional Center in Louisiana. As mentioned, Landor is a Rastafarian, and as part of his religious practice he maintains dreadlocks. Rastafarianism is a religious and spiritual movement that began in Jamaica in or around the 1930s, and many (but not all) practicing Rastafarians believe in the practice of growing their hair into dreadlocks that they do not cut.
Upon arriving at Laborde, Landor gave prison guards legal documents explaining that Rastafarian inmates must be allowed to keep their dreadlocks as a religious accommodation. Instead of following the law, one of the guards literally threw the legal documents in the trash. The prison’s warden ordered the guards to ignore Landor’s request to keep his dreads, and according to court documents, guards then “carried him into another room, handcuffed him to a chair, held him down, and shaved his head,” blatantly violating Landor’s rights.
As the case has made its way through the legal system, the prison officials have conceded that Landor’s rights were violated and the forced head shaving should never have happened. The legal question is whether a federal law, the Religious Land Use and Institutionalized Persons Act, gives Landor the right to sue the responsible warden and guards for money in their individual capacities as opposed to their official capacities. The extremely conservative 5th U.S. Circuit Court of Appeals ruled against Landor, holding that, even in an exceptionally terrible case of religious discrimination like this, Landor cannot seek damages (aka money) from the officials in their individual capacities.
You might be thinking that this seems like quite a technical question, and you’d be correct. It is. It’s not entirely clear how the Supreme Court will rule. Deciding that prison officials can be sued in their personal capacities for money if they violate an inmate’s rights might actually do something to deter those officials from violating inmates’ rights in the first place. What’s perhaps more interesting about this case is that the plaintiff is a religious minority, not a Christian, like the plaintiffs at the heart of many of the Roberts Court’s pro-religion rulings.
The Supreme Court has placed so much stock in religious belief that it’s been willing to essentially elevate the First Amendment’s Free Exercise Clause over its Establishment Clause. One would hope that the court’s sympathies would apply to all religions equally, especially in matters of truly egregious discrimination. However, since this case turns on more technical arguments about statutory construction and money damages, the court can potentially hide a disfavorable ruling for Landor behind blustering about the text of the statute at issue and jurisprudential principles of remedies.
As we’ve seen over the past nine months, minorities and people of color are hardly safe from the Christian nationalist authoritarianism overtaking the federal government. A sterling example of the federal government’s hostility toward anyone who won’t conform to white Christian nationalist ideals is Defense Secretary Pete Hegseth’s recent unhinged rant. The hour-long “speech” Hegseth gave to military leaders included Hegseth telling leaders that service members must be clean-shaven, stating, “Today, at my direction, the era of unprofessional appearance is over.” “No more beardos. The age of rampant and ridiculous shaving profiles is done.” Hegseth was directly attacking religious and medical waivers that overwhelmingly benefit minority faith service members, such as Sikhs, and service members of color.
We at FFRF are duly wary of religious exemptions, especially when they elevate the rights of religious people over the rights of others. However, beard and shaving-related accommodations harm literally no one. In the context of the military, permitting those with religious or medical needs to maintain a groomed beard does little to nothing to hurt others or imperil military readiness. Hegseth’s plan to end shaving accommodations is plain bigotry.
It remains to be seen how SCOTUS will rule in Landor or how the federal government will attempt to enforce its new discriminatory military shaving policy. What’s certain is that white Christian nationalism is a threat to every aspect of society — from prisons to the military and beyond — and that anyone who does not conform to the ideology’s rigid, racist ideals is a target.
Disclaimer: The views in this column are of the author and do not necessarily reflect those of the Freedom From Religion Foundation.
