Today, Notre Dame Law School’s Lindsay and Matt Moroun Religious Liberty Clinic filed an amicus brief on behalf of a coalition of religious groups, urging the U.S. Supreme Court to correct the denial of monetary damages to prisoners who suffer violations of their religious beliefs.
In Landor v. Louisiana Department of Corrections and Public Safety, a devout Rastafarian, Damon Landor, seeks monetary damages against the state prison officials who forcibly shaved his dreadlocks against his religious beliefs. Just three weeks before his scheduled release, the officials threw away a copy of a controlling court decision holding that Louisiana’s policy of cutting Rastafarians’ hair violated federal law and then pinned Landor down to shave his head.
The district court dismissed Landor’s claims, holding that the federal Religious Land Use and Institutionalized Persons Act does not provide for monetary damages against individual state officials.
After the Fifth Circuit affirmed that decision, a divided Fifth Circuit denied Landor’s petition for rehearing en banc. But six judges dissented from the denial, arguing that RLUIPA does authorize monetary damages—and the U.S. Solicitor General later urged the Supreme Court to take up the case. The Supreme Court agreed to hear the case, which will be argued on November 10, 2025.
In its amicus brief, the Clinic demonstrates that monetary damages are essential to the effective functioning of the remedial scheme Congress enacted in RLUIPA. The statute authorizes courts to award to successful religious claimants all “appropriate relief,” which has long been understood to include monetary damages.
As the Clinic’s brief makes clear, the availability of damages is especially important for incarcerated religious minorities, who are particularly likely to suffer mistreatment in prisons and jails.
“Damages are often the only form of relief that can remedy religious harms. A court order preventing government officials from violating RLUIPA does no good after a prisoner is released or moved to another facility,” said Meredith Kessler, staff attorney for the Religious Liberty Clinic. “The notion that there is nothing a court can do to help those whose suffer burdens on their religious exercise defies RLUIPA’s very goal of restoring sweeping protections for religious exercise.”
The Clinic filed the amicus brief on behalf the Bruderhof, an intentional community of Christians who suffered persecution for their conscientious objection in Nazi Germany; CLEAR (Creating Law Enforcement Accountability and Responsibility), legal nonprofit and clinic at the City University of New York School of Law that protects Muslim and other communities that are targeted by law enforcement under the guise of national security and counterterrorism; the Jewish Coalition for Religious Liberty (JCRL), a nondenominational organization of Jewish communal and lay leaders who seek to protect the ability of all Americans to freely practice their faith; and the Sikh Coalition, a nonprofit and nonpartisan organization dedicated to ensuring that members of the Sikh community are able to practice their faith without bias and discrimination.
“If people who are imprisoned are victims of egregious conduct towards their religion, they should be able to receive damages—else they have no real remedy. Given that Sikhs and other marginalized religious groups continue to have their rights trampled within the prison system, we support Mr. Landor's case as a means to secure justice for himself and strengthen protections like RLUIPA for all,” said Marissa Rossetti, staff attorney for the Sikh Coalition.
Notre Dame Law School students Cathy Kolesar and Brandon Enriquez contributed to this brief alongside Clinic attorneys.
“The opportunity to represent different religious communities in defense of religious freedom for all people—especially those most in need—is an irreplaceable learning experience for our students and, indeed, the very purpose of our Clinic,” said Professor John Meiser, director of Notre Dame’s Religious Liberty Clinic.
About the Notre Dame Law School Religious Liberty Clinic
The Lindsay and Matt Moroun Religious Liberty Clinic is a teaching law practice that educates, forms, and prepares Notre Dame law students to become the rising generation of religious liberty leaders by training students in the practice of the law as they defend religious freedom for all people.
Under the guidance of Law School faculty and staff, students work on a broad variety of legal matters to promote religious freedom on behalf of individuals and organizations of all beliefs—both domestically and abroad. The Clinic represents clients from all faith traditions to promote not only the freedom for people to hold religious beliefs but also their fundamental right to express those beliefs and to live according to them. Learn more about the work of the Clinic here.