For nearly two decades, Damon Landor never cut his hair. As a devout Rastafarian, he kept the Nazarite vow, letting his locks grow as an act of faith. Then, with about three weeks left on a five-month sentence, guards at a Louisiana prison handcuffed him to a chair and shaved his head. This week the Supreme Court decided he cannot sue them for it.
What Is the Nazarite Vow?
The vow reaches back to the Hebrew Bible, where in the Book of Numbers a Nazirite set himself apart for God by promising to avoid specific actions. The traditional vow has three components:
- Don't consume grapes (this prohibition includes grape byproducts like wine, vinegar, and raisins),
- Make no contact with the bodies of the dead,
- No cutting of the hair
Rastafari adherents to the Nazirite vow draw most on that last command, often pointing to the biblical story of Samson, a legendary warrior whose strength was stored in his hair. For believers, dreadlocks are not a style but a sign of devotion to Jah (God) and a tie to their African roots. They also stand as a rejection of what Rastafari call "Babylon", a shorthand for the worldly systems of oppression they trace from slavery and colonialism through to the prisons and police of today. Shearing the locks is akin to desecration, not personal grooming.
What Happened in Louisiana?
Landor served most of his term without incident. Two earlier facilities let him keep his hair, sometimes tucked under a rastacap, and one even amended its grooming policy to accommodate him. That changed after a transfer to the Raymond Laborde Correctional Center, with only three weeks left to serve on his sentence. At his intake into the facility, he explained his faith and handed over a 2017 federal appeals ruling that protected a Rastafarian prisoner's right to keep dreadlocks.
According to court records, the guard threw the paper in the trash and summoned the warden, Marcus Myers, who demanded documentation from Landor's sentencing judge. Landor offered to call his lawyer for it. "Too late for that," Myers replied, then ordered guards to take him to another room, where two held him down while a third shaved his head to the scalp. Landor later told ABC News that being strapped down and shaved "felt like I was [being] raped."
Why Did the Court Rule Against Him?
The case turned on a technical question, not on whether the shaving was wrong. Landor sued under the Religious Land Use and Institutionalized Persons Act, a law tied to federal funding: Louisiana's prison system agreed to follow it in exchange for federal money. Writing for the 6-to-3 majority, Justice Neil Gorsuch reasoned that this deal binds the department as an institution, but not the individual guards and warden, who never personally signed on to it. So Landor could name the prison system in his suit, but he cannot collect damages from the officers who held him down. Even the lower court that ruled against him had "emphatically" condemned his treatment.
What Did Each Side Say?
The three dissenting justices saw real danger in that outcome. Justice Ketanji Brown Jackson wrote that the decision leaves inmates like Landor "remediless," giving prison staff little reason to honor federal law even when handed proof of it. Landor's lawyers called the shaving "shocking, offensive, and lawless," and noted that dozens of religious groups across the spectrum had lined up behind him.
Notably, Louisiana never argued the shaving was acceptable. The state conceded the episode ran against religious freedom and fair treatment, and it amended its grooming policy so a repeat could not happen. What it would not do was pay Landor, or accept that its officers could be sued as individuals. Its defense rested on the law, not the conduct. State Attorney General Liz Murrill said, "Religious liberty is deeply important, and Louisiana has laws on the books protecting it."
A Faith the Court Usually Protects?
The result surprised some observers. In recent years this Court has often sided with religious claimants, including an inmate who asked his pastor to pray aloud at his execution. Those cases tended to involve Christian believers. Here, a Rastafarian seeking the same deference did not prevail, which raises a fair question about whether every faith meets the same welcome at the courthouse door.
Do Some Religions Have More "Freedom" Than Others?
When the Court agreed to hear the case last year, we noted that it could reshape religious protections for inmates of every belief. The ruling answers part of that, and not in Landor's favor. A right with no remedy starts to look thin. The same worry surfaces in other recent fights, including the military's removal of 180 faiths from its list of recognized traditions.
Rastafari is a small faith, and small faiths often test whether legal promises stretch to everyone or only the majority. Courts have wrestled over which religions a prison must formally recognize, and readers here have long asked a blunt question: do we actually have religious freedom when those who break it walk away untouched?
Where should the line fall between a prison's authority and a prisoner's faith? If a law guards a right, but offers no way to enforce it, does that right even exist? And how should people of every tradition answer when the smallest faiths are so often the ones left without recourse?
17 comments
-
Bishop William Dusenberry, DD
No religion (besides the Universal Life Church, — if that’s categorized as a religion) offers complete freedom — except the Universal Life Church.
-
ServantOfJudgement
If I'm a prison guard with a wife and kids, that mop is getting cut. I ain't digging through it for shivs and meth.
He violated his faith with a cocaine nose and a tweaker Friday night. Don't want the hair cut again? Lay off the narcotics when you book on out.
When we break the law we certain rights. We can't have special hairdos and religious robes in prison. This is all a no brainier. Of course the hair gets cut. Geez dummy.
-
James Riggle-Johnson
This is wrong on so many levels. There is no accountability here. The warden and guards should face consequences for violating this man's rights. They ignored the documentation he provided and refused to contact his attorney before cutting his hair.
What infuriates me most is the hypocrisy. If we are going to have religious freedom, it has to apply to everyone, not just the faiths that happen to be popular or familiar. A person's religious beliefs do not become less worthy of protection because they are incarcerated or belong to a minority faith tradition.
The courts have repeatedly stepped in to protect the religious rights of Christians, often bending over backward to ensure those rights are respected. Yet when a man practicing a minority faith has his religious beliefs violated, they suddenly seem far less concerned. Religious liberty either belongs to all of us or to none of us.
I read someone’s earlier comment that said, “the guards were doing it because he was Black and not really Christian.” I have to agree with that.
I'll remember stories like this the next time someone claims that Christianity is under attack in America.
-
The Right Reverend D. Batch
Sorry, you give up rights when you become a criminal. Serve your sentence, get released and grow it back, Also, don't reoffend.
-
-
Keoni Ronald May
The department of corrections has the last say.
The department of corrections policy, and, not the corrections officers, would have to be declared unconstitutional.
He had long hair throughout his incarceration and there did not appear to be a problem.
-
Reverend Paula Copp
This has nothing to do with his religion; it has everything to do with control and humiliation of the victim… may they get back what they inflict upon others!
-
Melinda Fulk
This makes me so angry. And I am willing to bet the guards were doing it because he was Black and not really Christian in their eyes. Hysteria Podcasting just did an excellent ripping apart of Justice John Roberts that is worth a listen if you want a good look at how his time as Chief Justice has led to much reduction in individual rights, especially if you aren't a fundamentalist Christian.
-
Elvin St. James
when you Abdicate your Freedom to Some Higher earthly Authority, All personal Belief Systems are Abdicated!
-
Dr Dennis Chevalier, MDiv, PhD, DDvin, ULC honorary DD
where did my comment go?
-
Rev. Miche'al Yosef Dixon
Once upon another lifetime I was a sheriff deputy in East Felicia Parish Sheriff's department (a tax payer funded drug cartel), then a , corrections officer for Louisiana Department of safety and corrections at DCI (another Drug cartel storage and distribution center) {quit and went to Mississippi Department of Corrections got paid twice as much with reduced from Sargent to corrections office & not as corrupt}. Louisiana does not obey any rights or boarders. In 2024 I watched a man cuffed to a chair and hair cut in exactly same manner at River Bend Corrections. Ivf seen and been men handcuffed beaten and raped brutally by guards and/or guards letting other prisoners. I filed a 1983 suite against guards at Vidala corrections center they hznc cuffed me beat me until I coughed blood 3 days, handcuffed naked to a bed raped by other prisoners. Judge said my rights not violated as "it was not done as punishment but for the guards pleasure". In my appeal the 5th circuit ruled "mister Dixon's rights do not matter as the constitution is only toilet paper with ink blots. Nov 2011. State of Louisiana although FBI, Mississippi, California, Missouri all said , not crime occurred. Louisiana has jurisdiction over those states and Federal government. Louisiana says, "nineteen years old is under the age of seventeen years old". "Anyone under 21 years old is a juvenile and it is illegal for a person over 21 to have sexual actions with that person." The current government Jeff Landry while Attorney General petition Congress three times to make Louisiana a prison state put a fence around the state. His petition Congress five times since becoming governor. Now as to the man assaulted by the rent-a-cops; coming from a raised Jewish faith, the Vow of the Nazarite is for Israelites only, if he actually has Israeli blood in his veins great. But then taking the vow and not following every single instruction to the letter will turn it into a curse; the very story of Samson is example. Yes, his hair untouched was a placebo to give him strength, however drinking wine and fornication his life was cursed with bad luck. Also when you take a vow of the Nazarite you set a time limit on how long that vow last. Yeshua (Jesus) took the vow for life, he drank grape/vinegar on the cross, most his hair ripped out at the torture session. Fulfilling the instructions best He could under the circumstances. Most give the vow for shorter time spans, 20-40 years time of studying and learning YHWH's plans for you. Further as an Israeli we are instructed "Let not a razer touch your head, not a razor touch thy face or between thy eyebrows." Exception given for medical quarantine procedures. Yes, the modern medical quarantine procedures are written straight from Mosaic Law.
-
Najah P Tamargo
Najah Tamargo-USA
This is disgusting and revolting! Religious beliefs are sacred in ANY faith, even the ones that are small and not adhered to by the mainstream of society. All faiths deserve RESPECT, even in prison!!!
-
Elizabeth Jane Erbe Wilcox
I find myself enraged by this. Wrong wrong wrong.
On the other hand, I despise the “sincerely held religious beliefs” trope.
Gives me something to think about. I’m not sure I can reconcile the two.
-
Dr. Zerpersande, NSC
Similar feeling here.
I’ve seen dreads in Jamaica. Month long vacations on several occasions. That picture was nothing like the dreads in Jamaica worn by the Rastas I saw throughout the country. They are decorative, ‘shaped’ versions. I remember seeing this one guy walking down the street in the Negril. His hair was below his knees. It was essentially one big rope as big as my bicep. A few little additional ropey, strands here and there, but basically one big rope. And all the ones that I saw were matted strands of one sort, size or another.
Bob Marley made reggae music popular and with it came a fad of growing those. It became a fashion. This guy were shaped. Carefully shaped. It showed a degree of vanity that the true rastas don’t have.
That being the claim of ‘sincerely held religious beliefs’ becomes similar to wearing a lowercase T on a necklace around your neck with the little fish symbol on your cap and yet all the while spewing racist hate and religious bigotry.
But it was still wrong to cut them off. Which have to recognize this is a black man in Louisiana. I’m generalizing some hot, but you have to admit that when you think of ‘prison guard in Louisiana’ the term ‘ignorant, racist redneck’ kind of springs to mind at the same time.
-
-
Colleen McAllister
This is wrong on many levels. Rastafarians worship.the same God we do. I'm not sure what their relationship with Jesus is, but that is between them and the Father. The prison should have enforced the court judgement even down to making the Warden and guards obey. What they did to this man is inexcusable. I sympathize with how he must feel. The Warden and guards who shaved his head need to be punished for this desecration.
-
Bishop William Dusenberry, DD
As Thomas Jefferson clearly implied— in his “Declaration of Independence” Nature’s God needs no worshiping; however if anyone needs to worship anything— worship the Sun, because the Sun (via, Nature) is the source of all life.”
-
-
Nicholas J Page
Rastafarians don't cut their dreadlocks according to their religion yet this guys hair was shaved that's a violation of his faith and also he had been humiliated in the worse possible way it's disgusting and degrading.
I believe it is inherently wrong to do this to this man. I also believe it is inherently wrong to remove 180 religions from being recognized by our military. If this country supports religious freedom, it must practice religious freedom for and from ALL RELIGION! It’s like saying, we’re all created equal but some are more equal than others.