Landor v. Louisiana Dept of Corr, 82 F.4th 337

Damon Landor, a devout Rastafarian who kept a Nazarite vow (long hair), was shaved at Raymond Laborde Correctional Center after refusing to produce court documentation of his religious practice.
Prior incarcerations at other Louisiana facilities had accommodated his religious grooming; RLCC staff allegedly ignored proof of prior accommodations and Fifth Circuit precedent and forcibly shaved him.
Landor sued the Louisiana Department of Corrections, the prison, Secretary James LeBlanc and Warden Marcus Myers in their official and individual capacities under RLUIPA, § 1983, and state-law theories.
The district court granted defendants’ motion to dismiss Landor’s RLUIPA claims against officials in their individual capacities, relying on Fifth Circuit precedent (Sossamon) that bars such monetary claims.
Landor appealed, arguing (1) RLUIPA permits individual-capacity monetary damages, (2) Tanzin v. Tanvir abrogated Sossamon, or (3) Sossamon’s Spending Clause analysis was wrongly decided.
The Fifth Circuit affirmed, holding Sossamon remains controlling and RLUIPA does not authorize money damages against officials sued individually.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether RLUIPA authorizes money damages against officials sued in their individual capacities	RLUIPA’s text allows suits against “any other person acting under color of state law,” so individual damages are available	Sossamon controls: RLUIPA is Spending Clause legislation that creates liability only for fund recipients (states), not individual officials	RLUIPA does not permit individual-capacity money damages; affirm Sossamon
Whether Tanzin v. Tanvir (RFRA) abrogates Sossamon’s holding on RLUIPA	Tanzin’s recognition of individual damages under RFRA means identical text should be read the same in RLUIPA	Tanzin dealt with RFRA (Fourteenth Amendment basis); RLUIPA is Spending Clause-based and raises different constitutional/contract-notice concerns	Tanzin does not abrogate Sossamon; different statutes and powers involved
Whether Sossamon’s Spending Clause analysis is undermined by Sabri v. United States	Sabri shows Congress can reach individuals under the Spending Clause, so RLUIPA can impose individual liability	Sabri involved criminal protections of federal funds (anti-bribery) and is inapposite to civil RLUIPA claims protecting religious rights	Sabri is inapplicable; Sossamon’s Spending Clause rationale stands

Sossamon v. Lone Star State of Texas, 560 F.3d 316 (5th Cir. 2009) (held RLUIPA does not permit individual-capacity damages)
Sossamon v. Texas, 563 U.S. 277 (2011) (Supreme Court decision addressing remedies under RLUIPA)
Tanzin v. Tanvir, 141 S. Ct. 486 (2020) (RFRA authorizes money damages against federal officials sued individually)
Ware v. Louisiana Dept. of Corrections, 866 F.3d 263 (5th Cir. 2017) (Fifth Circuit precedent on Louisiana policy and Rastafarian hair under RLUIPA)
Sabri v. United States, 541 U.S. 600 (2004) (upheld criminal statute under Spending Clause to protect federal expenditures)
Holt v. Hobbs, 574 U.S. 352 (2015) (distinguishes statutory bases of RFRA and RLUIPA)