In 2020, Damon Landor, a devout Rastafarian, was sentenced to prison for 5 months for drug possession. While serving his term, he vowed to “let the locks of the hair of his head grow.” Landor had been growing his hair for nearly two decades per his religious Nazarite vow and exclaimed, "during the entire period of one’s Nazarite vow, no razor may be used on one’s head." While serving his term, he had first been incarcerated at two facilities, both of which respected his vow and allowed him to keep his hair in a “fast cap.” In the final 3 weeks of his sentence, he was transferred to Raymond Laborde Correctional Center (RLCC) and told prison officers that he had been practicing Rastafarian. He provided them with state and federal forms that outlined his prior religious accommodations for his hair and a copy of the Supreme Court decision in Ware v. Louisiana Department of Corrections. Upon receiving the copy, an intake officer threw it in the trash and summoned Marcus Myers, the Warden, who demanded documentation from his sentencing judge. Landor told Myers that he could request the documentation from his lawyer to which Myers said “it was too late for that. He then proceeded to bring him to another room, handcuff him to a chair, and shave his hair while holding him down. 
After being released from prison, Damon Lander sued the Louisiana Department of Education under the Free Exercise Clause in the case of Landor v. Louisiana Department of Corrections, arguing the Religious Land Use and Institutionalized Persons Act (RLUIPA) -a federal law created to protect the religious rights of inmates who lose rights while incarcerated- was violated. Though this act is statutory, it was created as an extension of the Free Exercise Clause to address burdens on religious exercise that are not fully guaranteed by the Constitution. Under this act, the government must show that a restriction on religious exercise: (1) serves a compelling state interest and (2) is the least restrictive in achieving the interest. Landor argues that neither of these premises were met and therefore he has the right to freely exercise his religion, which includes his dreadlocks as a religious practice. To receive relief, he sought to recover damages against state government officials.
The constitutional issue in Landor v. Louisiana Department of Corrections deals with the Free Exercise Clause, which “protects citizens' right to practice their religion as they please, so long as the practice does not run afoul of a "public morals" or a "compelling" governmental interest.” This clause prohibits the government from enacting policies or laws that interfere with an individual's ability to freely practice their religion. However, the scope of this clause becomes complicated in prisons, where restrictions on religious practice can be justified. Nevertheless, the central issue is whether the Louisiana Department of Corrections and its prison officers violated Landors right to freely exercise his religion when they forcibly cut his dreadlocks off, despite him making it clear that he is a practicing Rastafarian. Landor argues that by forcibly shaving his hair, RLCC put a substantial burden on his religious exercise.
When Holt v. Hobbes is applied to the case at hand, there are stark parallels. In Hobbes, Gregory Holt, who was an inmate at the Arkansas Department of Corrections, had been practicing Salafi Muslim. While serving his term, he sought an injunction and temporary relief from the correction facility grooming policy, which allowed for only quarter-inch beards and mustaches for diagnosed medical purposes. Holt argued that the grooming policy significantly burdened his ability to grow a bird, which was essential to the practice of his religion. This policy, he contended, therefore violated the Religious Land Use and Institutionalized Persons Act (RLUIPA). In a 9-0 majority opinion, the Court ruled that the Arkansas Department of Corrections grooming policy violated the RLUIPA, undermining the Free Exercise Clause, by preventing Holt from growing a one-half-inch beard per his religious beliefs. They exclaimed that the RLUIPA allows prison officials to test the sincerity of one's religious beliefs, and if they were found to be science, an accommodation can be made. In this case, Holt's religious beliefs were found to be sincere, and therefore he met the standard of accommodation. Further, the Court argued that prison officers failed to meet the burden of proof. They had the burden to prove that preventing inmates from growing beards constituted a compelling government interest and that this interest was the least restrictive means of interference, however, they did not satisfy this burden. This landmark case, which defines an inmate's religious rights in prison, can be compared to Landor. In the case at hand, Landor had been a devout Rastafarian who made a vow to not cut his hair for religious purposes. He made it very clear that he was sincere in his beliefs of not cutting his hair through both practice and telling prison officers that he had received religious accommodations in other facilities. Given that Hobbes was allowed to receive a religious accommodation for growing his beard under the RLUIPA, Landor should have received the same accommodation.
I strongly believe that this case should be ruled in favor of Landor. It is worth noting that the government can limit inmates' constitutional rights (freedom). However, they still must act in accordance with the Constitution. In analyzing many different prisons across the United States, Congress found significant evidence of religious discrimination, especially against “non-mainstream” faiths. For this reason, the RLUIPA was created to protect inmates' religious rights and practices when the First Amendment cannot do so in prisons. It primarily serves as an extension of the Free Exercise Clause. Under this act, the government must show that a restriction on religious exercise: (1) serves a compelling state interest and (2) is the least restrictive in achieving the interest. If the religious practices are sincere and these premises are not met, the government may not impose a substantial burden on religious exercise. In taking the Free Exercise Clause and RLUIPA into account, I believe that it is clear that the prison officers violated Landor’s right to freely exercise his religion in a stark manner. After asking the officers for a religious accommodation, they first threw out the piece of paper that contained a court case holding that Louisiana's policy of cutting hair violated the RLUIPA in front of Landor. They then pinned him down and shaved his head. After the fact, the officers failed to provide a compelling governmental interest in denying Landor's accommodation and consequently shaving his head. Rather than acting neutrally, it appears these officers acted hostile toward religion. The mere fact that two other facilities recognized the sincerity of his religious beliefs and allowed him to grow his hair makes it seem that officers at RLCC took punitive measures rather than security measures. Additionally, they failed to explore any alternatives for Landor and instead immediately resorted to physical force, and therefore, neither of the premises of RLUIPA were met. Ultimately, the officers unlawfully put a substantial burden on Landor's religious rights.
Therefore I ask you all to consider these questions. When the prison Warden shaved Landor's hair, did he unlawfully burden his right to freely exercise his religion? Does the RLUPIA extend constitutional protection toward religion in this case? What do you guys think? Should religion be accommodated in prison and if so to what extent?
6 comments:
I agree with your assessment to a certain extent. You make a strong argument by comparing the case to Holt. However, I don't think the fact that other prisons confirmed the sincerity of Landor's convictions is constitutionally applicable in defending him. Prisoners lose the right to bear arms and vote when they are convicted. It comes down to whether or not the prison had a compelling state interest in shaving his head. The dialogue and the events that took place when they shaved his head makes it seem like the prison guards were acting harshly. But what if there is a state interest in preventing inmates from having dreadlocks? There is a reason prison's require a certain hair length. Dreadlocks are dense and you can hide a weapon or something you aren't supposed to have in them. Short hairstyles also help maintain good hygiene and prevent the spread of lice and other issues. Landor seems to have a clean record in prisons and is not a violent criminal based on his drug charge history. Yet, I would argue ruling in favor of Landor could have a slippery slope effect for violent criminals in the future and allowing him to keep his dreadlocks could pose a threat to the safety and health of guards and other prisoners. Therefore I believe the prison has the right to shave a prisoner's head regardless of their religious convictions.
I disagree with your argument that the court should rule in favor of Landor because as an inmate in a prison the ability to express religious traditions is limited to what is logistically able to be accommodated in the prison. For this reason, despite potentially infringing on an individuals religious beliefs the court should not rule in favor of Landor. In this case, the religious beliefs and traditions of inmates take a backseat to the opportunities for religious expression based on the operational functions of the prison.
I agree that the case should be ruled in favor of Damon Landor. The officers at RLCC violated his rights under the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the Free Exercise Clause by forcibly shaving his hair without demonstrating a compelling state interest or using the least restrictive means. Their actions disregarded Landor’s sincere beliefs and prior accommodations, highlighting hostility toward religion and undermining constitutional protections for religious exercise in prisons. I also don't think that the status of inmate makes them lose their first amendment rights.
By forcibly shaving this man's hair, he is being explicitly discriminated against and having his constitutional freedom to exercise his religion violated. Although he is a prisoner, there is no compelling interest to shave a person's hair when it goes deliberately against one's religion, even when they are behind bars. It is important to recognize the freedoms of an American, which are limited when imprisoned, but not all vetoed by their inmate status.
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