America Has Always Cut the Hair of the People It Wanted to Erase.

The Supreme Court just ruled that a Rastafarian man cannot sue the prison guards who shaved his head against his will. Forced haircuts have a long history in America.

Jun 24, 2026

On Tuesday, the Supreme Court ruled that Damon Landor could not sue the Louisiana prison guards who held him down and shaved his head. Landor, a Rastafarian who took a vow not to cut his hair and had kept it for almost twenty years, entered prison to serve a five-month sentence on a drug conviction and carried with him a copy of a federal court decision that protected his right to keep his locks. When officials moved him to a new facility with three weeks left to serve, he handed that decision to an intake guard. The guard threw it in the trash and called the warden, who ordered the haircut. Two guards cuffed Landor to a chair while a third shaved him to the scalp.

The justices split 6 to 3, and Justice Neil Gorsuch wrote for the majority that the federal law protecting prisoners’ faith does not let inmates sue the individual officials who violate it. Landor lost, even though every justice admitted that the guards had wronged him. The guards did to Landor what white Americans have done for centuries to people they wanted to strip of their identity.

The Court Ruled Against Landor

Landor sued under a 2000 federal law, the Religious Land Use and Institutionalized Persons Act, which requires prisons that accept federal money to respect the faith of the people they hold. Gorsuch reasoned that the law works like a contract. Louisiana took the federal funds and agreed to the terms, but the individual guards never signed anything, so Landor could not collect damages from them.

Justice Ketanji Brown Jackson wrote the dissent and called the result exactly what Congress had set out to prevent. She warned that prisoners whose religious rights are violated will now often walk away with nothing, and that guards who break the law will have little reason to follow it the next time. Even the Trump administration urged the Court to let Landor’s suit move forward, but he still lost.

Cutting Hair as Identity Erasure

What the guards did to Landor would have been familiar to generations of Native children. For many tribal nations, hair carried spiritual and cultural meaning, and people traditionally cut it only to mark grief after a death. Long hair signaled a person’s identity and connection to ancestry.

Starting in the late nineteenth century, the federal government and churches ran boarding schools to erase that heritage. Administrators took Native children from their families and set out to remake them in a Christian, Euro-American mold under the slogan “kill the Indian, save the man.” They cut new arrivals’ hair almost immediately, often calling it a guard against lice. Photographers documented the change in before-and-after portraits, showing children who arrived with long hair and reappeared days later cropped close. The children understood that the people in charge meant to take the rest of their identity too.

Enslavers in America had done the same thing earlier. They shaved the heads of enslaved Africans to punish and humiliate them, and they controlled who could cut Black hair at all. Enslavers often limited Black barbers in the antebellum South to serve only white men, which gave them control over the relationship between Black people and their own bodies. The people in power understood that taking someone’s hair without consent cut deeper than the hair itself.

The Court Protects Some Religious Claims

The Court provided no remedy for Landor, but in recent years, they have repeatedly protected Christian practices. In 2022, the justices sided with a public-school football coach who prayed at midfield after games and with a death-row inmate who wanted his pastor to lay hands on him and pray aloud as he died. In 2014, the Court upheld the Christian prayers that a town council used to open its meetings. In 2019, it allowed a forty-foot Latin cross to stand on public land as a war memorial.

These cases involved different laws than Landor’s, and those legal differences are legitimate. However, law professor Caroline Mala Corbin has documented how, in moving toward government-backed Christianity, the justices drew on an older American habit of treating Christianity as the default faith of a real citizen. For most of the country’s history, courts used Christianity to help define who counted as white and who counted as American, and they placed Muslims and other non-Christians outside that line. Rastafari began in 1930s Jamaica as a Black response to colonial rule, and has never been close to what these courts counted as American.

Dangerous Precedent for Future Prisoners

After Tuesday, prisoners will have little redress if guards violate their faith. As Justice Jackson pointed out, the Court left people like Landor depending on the goodwill of the guards most likely to ignore them. Prisoners who practice minority faiths, including Rastafarians and Muslims, will feel that absence first.

Landor finished his sentence with a shaved head, and he left prison to find that the highest court in the country would not give him a way to hold anyone responsible. “I am disappointed but not defeated,” he said after the ruling. “What happened to me should not happen to anyone else.”

His lawyers pointed out that Congress could still amend the law so the next prisoner has a way to fight back. Until that happens, the guards who shaved Landor’s head legally owe him nothing.

References

Nina Totenberg, “Supreme Court Rules That Prison Guards Can’t Be Sued for Shaving Rastafarian’s Head,” NPR, June 23, 2026.
Ann E. Marimow, “Supreme Court Bars Lawsuit After Prison Guards Shaved Inmate’s Dreadlocks,” New York Times, June 23, 2026.
Al Jazeera Staff, “US Supreme Court Says Rastafarian Man Shaved by Prison Guards Can’t Sue,” Al Jazeera, June 23, 2026.
Sophia Turningrobe, “America’s Native American Boarding Schools: Hair Cutting,” Sister Sky, November 2, 2023.
Amanda Ross, “Across the U.S., Native American Hair Is Subjected to Culture-Erasing ‘Grooming Policies,’” The Zoe Report, December 15, 2023.
Sylvia R. Karasu, “The Weaponization of Hair,” Psychology Today, November 29, 2023.
Elias Rodriques, “Barbering for Freedom,” n+1, September 28, 2015.
Caroline Mala Corbin, “The Supreme Court’s Facilitation of White Christian Nationalism,” Alabama Law Review 71, no. 3 (2020): 833.
Tom Gjelten, “White Supremacist Ideas Have Historical Roots in U.S. Christianity,” NPR, July 1, 2020.