The Disturbing Prison Abuse Case Coming Before the Supreme Court

A Fifth Circuit panel described what happened next. “Upon arrival, Landor was met by an intake guard,” Judge Edith Brown Clement wrote for the panel in Landor’s case in 2023. “Acting preemptively, Landor explained that he was a practicing Rastafarian and provided proof of past religious accommodations. And, amazingly, Landor also handed the guard a copy of our decision in [Ware], which held that Louisiana’s policy of cutting the hair of Rastafarians violated RLUIPA.

“Unmoved by our caselaw, the guard threw Landor’s papers in the trash and summoned RLCC’s warden, Marcus Myers,” Clement continued. “When Myers arrived, he demanded Landor hand over documentation from his sentencing judge that corroborated his religious beliefs. When Landor couldn’t instantly meet that demand, two guards carried him into another room, handcuffed him to a chair, held him down, and shaved his head.”

Landor completed his sentence and promptly filed a lawsuit against the state, the warden, and other officials for violating his First and Fourteenth Amendment rights under RLUIPA, among other things. He argued that the prison’s treatment of him—made all the more egregious by its willful disregard of a Fifth Circuit decision that was literally handed to the guard—violated his constitutional rights and his religious freedom.