2026年6月23日 / 美国东部时间上午11:55 / 哥伦比亚广播公司新闻
华盛顿讯——美国最高法院周二驳回了路易斯安那州一名前囚犯起诉州监狱官员的诉求，此前官员们剃除了他的长发绺，这一行为违反了他的宗教信仰。
最高法院以6票对3票的意识形态分歧投票裁决驳回了达蒙·兰多的诉求，三名自由派法官持反对意见。尼尔·戈萨奇大法官撰写了多数方意见。
兰多是一名虔诚的拉斯特法里教派信徒，他因监狱警卫剃光了他的头发，试图起诉路易斯安那州惩教与公共安全部及监狱官员，指控其违反《宗教土地使用和机构化人员法》（简称RLUIPA）。尽管下级法院对兰多遭遇的待遇表示谴责，但两家不同法院的法官均驳回了他的诉讼请求。最高法院的裁决维持了美国第五巡回上诉法院的判决，驳回了兰多恢复对涉事官员诉讼的请求。
戈萨奇在意见中写道，兰多“没有针对这些官员提起联邦RLUIPA诉讼的诉因。根据支出条款，国会缺乏直接对他们施加责任的监管权力，只能依赖对方的同意。而由于这些官员从未同意承担此类诉讼的责任，兰多先生的诉讼无法对他们继续推进，正如针对从未订立合同的被告提起的违约之诉无法得到受理一样。”
此次裁决对主张宗教权利遭到侵犯的原告来说是罕见的失利。近年来，最高法院多次站在宗教团体一边，包括2022年的一项裁决，支持一名得克萨斯州囚犯请求牧师在其行刑期间按手并当众祈祷的诉求。
在由索尼娅·索托马约尔大法官和埃琳娜·卡根大法官联名的反对意见中，凯坦吉·布朗·杰克逊大法官驳斥了多数方“全盘认可合同类比”的做法，并警告称，该裁决将导致像兰多这样在狱中遭遇宗教权利侵犯的囚犯“求告无门”。
“侵犯囚犯法定权利的行为很可能会频繁发生，因为由国家赋予权力的监狱官员几乎没有动力遵守联邦法律，哪怕法律白纸黑字摆在他们面前，”杰克逊写道。
这起名为兰多诉路易斯安那州惩教与公共安全部的案件于2020年引发，当时兰多即将服完五个月的刑期。作为一名虔诚的拉斯特法里信徒，兰多发誓“留起头发绺”，这一被称为拿细耳人誓愿的信仰他已坚守了近20年。
在入狱的头四个月里，两家监狱都允许兰多留长发或佩戴“拉斯特帽”。但在兰多被转移到雷蒙德·拉博德惩教中心服刑剩余三周后，情况发生了变化。兰多告诉该监狱的收押警卫自己是一名活跃的拉斯特法里信徒，并向警卫提供了宗教住宿申请的证明。他还向警卫出示了2017年第五巡回上诉法院的一份裁决副本，根据法庭文件，该裁决认定路易斯安那州剃除在押拉斯特法里信徒头发的政策违反了RLUIPA。
但据兰多的律师称，监狱警卫将这份裁决扔进了垃圾桶，将兰多铐在椅子上并剃光了他的头发。
兰多依据RLUIPA起诉了监狱典狱长和警卫，该法律旨在保护被关押在机构中的个人的宗教权利。一名联邦法官驳回了此案，认定该法律不允许对州政府官员个人提起损害赔偿诉讼。第五巡回上诉法院的一个三人法官小组维持了这一判决。
尽管上诉法院“强烈谴责”了兰多所遭遇的待遇，但法院表示，该巡回法院2009年的一项裁决终结了他的诉讼。在早前的这项裁决中，第五巡回法院认定RLUIPA不允许以个人身份对官员提起诉讼。随后，第五巡回法院全体法官拒绝重审兰多的案件。
特朗普政府在这场纠纷中支持兰多，在法庭文件中警告称，如果囚犯无法对以个人身份被起诉的政府官员获得金钱赔偿，将会削弱RLUIPA的执法力度。
Supreme Court rules Rastafarian ex-inmate can’t sue prison officials for shaving dreadlocks
June 23, 2026 / 11:55 AM EDT / CBS News
Washington — The Supreme Court on Tuesday rejected a former Louisiana inmate’s effort to sue state prison officials after they shaved his dreadlocks in violation of his religious beliefs.
The high court divided 6 to 3 along ideological lines in ruling against Damon Landor, with the three liberal justices in dissent. Justice Neil Gorsuch authored the opinion for the majority.
Landor, who is a devout Rastafarian, sought to sue the Louisiana Department of Corrections and Public Safety and prison officials for violations of the Religious Land Use and Institutionalized Persons Act, or RLUIPA, after prison guards shaved his head. While lower courts condemned Landor’s treatment, judges on two different courts dismissed his claims. The Supreme Court’s ruling upholds the decision from the U.S. Court of Appeals for the 5th Circuit rejecting Landor’s effort to revive his suit against the officers.
Landor, Gorsuch wrote, “does not have a federal RLUIPA cause of action against the officers. Under the Spending Clause, Congress lacks regulatory authority to impose liability on them directly and must depend instead on consent. And because they never agreed to answer suits like this one, Mr. Landor’s case cannot proceed against them any more than a breach of contract action might proceed against a defendant who never formed a contract.”
The ruling is a rare loss for a plaintiff arguing violations of his religious rights. In recent years, the high court has repeatedly sided with religious parties, including in a 2022 decision in favor of a Texas inmate who requested his pastor lay hands on him and audibly pray during his execution.
In a dissenting opinion joined by Justices Sonia Sotomayor and Elena Kagan, Justice Ketanji Brown Jackson rejected what she said was the majority’s “full-throated endorsement of a contract analogy,” and warned its decision will leave prisoners like Landor whose suffer violations of their religious rights while incarcerated “remediless.”
“Encroachments on prisoners’ statutory rights are likely to happen with fair frequency, as state-empowered prison officials will have little incentive to abide by federal law, even if it is handed to them on a piece of paper,” Jackson wrote.
The case, known as Landor v. Louisiana Department of Corrections and Public Safety, arose in 2020, when Landor had nearly completed a five-month prison sentence. As a devout Rastafarian, Landor pledged to “let the locks of the hair of his head grow,” known as the Nazarite Vow, which he had upheld for nearly 20 years.
For the first four months of his incarceration, two prisons had permitted Landor to keep his hair long or under a “rastacap.” But that changed after Landor was transferred to the Raymond Laborde Correctional Center for the remaining three weeks of his sentence. Landor told an intake guard at the facility that he was a practicing Rastafarian and provided the guard with proof of his religious accommodations. He also gave the guard a copy of a 2017 ruling from the U.S. Court of Appeals for the 5th Circuit, which found Louisiana’s policy of cutting the hair of incarcerated Rastafarians violated the RLUIPA, according to court papers.
But prison guards threw the decision in the trash, handcuffed Landor to a chair and shaved his head, his lawyers said.
Landor sued the prison warden and guards under the RLUIPA, which protects the religious rights of individuals confined to institutions. A federal judge dismissed the case, finding that the law does not allow for damages against individual state officials. A three-judge panel of judges on the 5th Circuit upheld that decision.
While the appeals court “emphatically” condemned Landor’s treatment, it said a 2009 decision in the circuit ended his case. In that earlier ruling, the 5th Circuit held that the RLUIPA doesn’t permit lawsuits against officers in their individual capacities. The full 5th Circuit then declined to rehear Landor’s case.
The Trump administration backed Landor in the dispute, warning in court papers that if inmates could not obtain money damages in actions against government officials sued in their individual capacities, it would undermine RLUIPA’s enforcement.
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