A Supreme Court case about dreadlocks could end up gutting Medicaid

The U.S. Supreme Court heard arguments Monday in a case that tests the limits of religious freedom protections for inmates — and, potentially, the broader power of Congress to attach conditions to federal funding for states.

At the center of Landor v. Louisiana Department of Corrections is Damon Landor, a Rastafarian who says prison officials violated his faith when they forcibly shaved his head while he was serving a five-month sentence for drug charges. Landor’s religion forbids him from cutting his hair.

Before the incident, Landor reportedly showed prison officials a copy of a federal court decision affirming that inmates have a right, under federal religious liberty law, to maintain their hair in accordance with their beliefs. Despite that, officers handcuffed him to a chair and shaved his head.

Landor sued the Louisiana prison officials responsible, seeking monetary damages under the Religious Land Use and Institutionalized Persons Act (RLUIPA). The issue now before the Supreme Court isn’t whether his rights were violated — that much appears clear — but whether he can personally sue the officials who violated them.

A Divided Court, and Conflicting Priorities

During oral arguments, several of the Court’s conservative justices appeared skeptical that Landor could collect damages from individual prison officials. While the Court has generally been sympathetic to religious liberty claims — particularly those brought by Christian plaintiffs — this case touches two areas where conservative jurists have tended to rule narrowly: personal liability for government officers and the scope of Congress’s spending power.

The first issue concerns whether individuals can sue government officials directly for violating their rights. The Supreme Court’s Republican-appointed majority has often been reluctant to expand such lawsuits, arguing they could deter effective law enforcement.

The second issue involves Congress’s ability to require states that receive federal funds — such as prisons accepting federal grants — to meet specific conditions. RLUIPA operates under that framework. But the Court’s majority has signaled interest in restricting Congress’s authority to impose these types of funding conditions.

As a result, even though justices such as Amy Coney Barrett called the prison’s treatment of Landor “egregious,” the Court may still rule against him. Chief Justice John Roberts noted that while the state agreed to RLUIPA’s terms by accepting federal funds, individual prison officers were not direct parties to that agreement — a technical distinction that could shield them from liability.

Why Take the Case?

Given that lower federal courts have uniformly ruled that inmates like Landor cannot collect damages under RLUIPA, it’s unclear why the Supreme Court agreed to review the case. Typically, the Court intervenes only when lower courts are divided or when justices intend to change the law.

Some observers believe the justices may see this case as an opportunity to redefine the balance of power between Congress and the states.

Potential Ripple Effects for Medicaid and Beyond

Two years ago, in Health and Hospital Corporation v. Talevski (2023), the Court affirmed that individuals could sue to enforce certain rights under federal Medicaid law. But that precedent may now be in jeopardy.

In a more recent ruling, Medina v. Planned Parenthood (2025), Justice Neil Gorsuch’s majority opinion suggested new limits on the ability of individuals to sue under federal spending programs — describing such laws as “especially unlikely” to be enforced through private lawsuits.

If the Court further restricts Congress’s power in the Landor case, it could affect not just inmates but millions of Americans who rely on federally funded programs like Medicaid.

During Monday’s arguments, Justice Ketanji Brown Jackson warned that ruling against Landor could weaken protections for patients and other beneficiaries of federal aid. Still, several justices appeared intent on curbing what they view as excessive federal reach.

Justice Gorsuch floated a series of hypotheticals — asking whether Congress could, for example, make university coaches personally liable for policies about transgender athletes, or make state employees liable for obtaining abortions. Those examples do not reflect current law, but they hint at the majority’s unease with how far Congress can extend liability through federal funding.

The Stakes

While Landor’s personal case centers on a clear act of religious discrimination, the Court’s decision could extend far beyond his situation. Depending on how broadly the justices rule, the case could reshape the boundaries of religious rights, law enforcement accountability, and the federal government’s power over state-run programs.

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