Tangle - The Supreme Court’s religious liberties ruling.

Episode Date: June 25, 2026

On Tuesday, the Supreme Court ruled 6–3 that federal law protecting prisoners’ religious exercise does not extend to a lawsuit brought by an incarcerated Rastafarian man who sought damages after prison officials forcibly shaved his head. The man, Damon Landor, sued both the Louisiana Department of Corrections and several of its officers individually under the Religious Land Use and Institutionalized Persons Act (RLUIPA), which defines the religious rights of people held in institutions that receive federal funding. However, the Court’s majority found that the law does not apply to the prison officials named in the suit, as they had not entered into a formal agreement with the federal government. Ad-free podcasts are here!To listen to this podcast ad-free, and to enjoy our subscriber only premium content, go to ReadTangle.com to sign up!Mamdani, Gabbard, and some media controversy.On this week’s episode of Suspension of the Rules, the team wades into the wider implications of Mamdani’s kingmaking in NYC, the controversy surrounding Tulsi Gabbard’s supposed association with a “cult leader,” and a debate about whether Tara Palmeri should have published an interview excerpt a congresswoman asked her to remove. You can watch it ⁠ ⁠⁠here⁠⁠⁠You can read today's podcast⁠ ⁠⁠here⁠⁠⁠ and today’s “Under the radar” story ⁠here⁠ and today’s “Have a nice day” story ⁠here⁠.You can subscribe to Tangle by clicking here or drop something in our tip jar by clicking here. Take the survey: What do you think of the Supreme Court’s ruling? Let us know.Our Executive Editor and Founder is Isaac Saul. Our Executive Producer is Jon Lall.This podcast written by: Audrey Moorehead and audio edited and mixed by Dewey Thomas. Music for the podcast was produced by Diet 75.Our newsletter is edited by Managing Editor Ari Weitzman, Senior Editor Will Kaback, Lindsey Knuth, Bailey Saul, and Audrey Moorehead. Hosted on Acast. See acast.com/privacy for more information.

From executive producer Isaac Saul, this is Tangle. Good morning, good afternoon, and good evening. And welcome to the Tangle podcast, a place where you get views from across the political spectrum, some independent thinking, and a little bit of our take. This is associate editor, Audrey Moorhead, and it's my favorite time of the political year, the end of the Supreme Court's term, when the court releases its final and often most consequential opinions in batches. Today I'm writing about an under-the-radar case the Tangle team has been watching really closely, a decision on whether a Louisiana-Rastafarian man could sue prison guards for violating his religious liberties by cutting off his dreadlocks. Then read on through a deeper dive into a 1990 Supreme Court decision on whether states can regulate religious conduct, an investigation into AI chatbot ideological bias, and our round-up of the stories we didn't cover. I hope you're excited for today's edition, and with that I'll pass it off to John.

Thanks, Audrey, and welcome everybody. Here are your quick hits for today. First up, the Supreme Court ruled six to three that the Trump administration can remove temporary protected status for Haitian and Syrian immigrants, allowing them to be deported. In a separate six-three decision, the court ruled that the administration can turn away asylum seekers before they cross the southern border into the United States. Number two, 7.2 magnitude and 7.5 magnitude earthquakes struck Caracas, Venezuela, killing at least 100. 164 people and injuring 971 as of Thursday morning. The death toll is expected to rise as the emergency response continues. Number three, the Commerce Department reported that the Personal Consumption Expenditures Price Index rose 4.1% on an annual basis in May, the highest rate increased since April 2023, while core inflation, excluding food and energy prices, rose 3.4%. Inflation rose 0.4% on a monthly basis. Number four, the Trump administration requested $87.6 billion in supplemental funding from Congress, primarily for costs related to the Iran War.

Number five, a federal judge blocked most provisions in President Donald Trump's executive order on elections issued in March 2025, including one measure that would have created a proof of citizenship requirement for voter registration for violating state and congressional election authority. And number six, postmaster General David Steiner testified at a Senate committee. hearing that under a proposed Trump administration rule, the Postal Service will not deliver mail and ballots in states that do not share voter data with the federal government. The Supreme Court has rejected a former Louisiana inmate's effort to sue state prison officials after they forcibly shaved his dreadlocks in violation, he says, of his religious beliefs. In a six-three vote divided right along ideological lines, the justices ruled that Damon Landor could not sue the individual officers responsible for doing this. The underlying

incident took place back in 2020 when Landers said that his dreadlocks were protected under a federal religious freedom law. According to his lawsuit, two guards then handcuffed him to a chair and proceeded to shave his head. On Tuesday, the Supreme Court ruled six to three that federal law protecting prisoners' religious exercise does not extend to a lawsuit brought by an incarcerated Rastafarian man who sought damages after prison officials forcibly shaved his head. The man, Damon Lander, sued both the Louisiana Department of Corrections and several of its officers, individually under the Religious Land Use and Institutionalized Persons Act, which defines the religious rights of people held in institutions that receive federal funding.

However, the court's majority found that the law does not apply to the prison officials named in the suit, and they had not entered into a formal agreement with the federal government. For context, in 2020, Lander was transferred to Raymond Labord Correctional Center in Louisiana while serving a five-month sentence for drug possession. As a member of Rastafari, a religion originating in Jamaica, which maintaining dreadlocks fulfills a religious vow, Lander determined never to cut his hair. However, prison guards attempted to shave his head upon arrival at the new facility. He protested and showed a prison guard a copy of an appellate court decision, holding that Arluipa

prohibited the prison from removing his dreadlocks. He was eventually handcuffed and shaved after officials dismissed his complaints. Afterward, he filed a suit seeking monetary damages from the Department of Corrections and prison officials. A district court and the U.S. Court of Appeals for the Fifth Circuit dismissed the claims against the court. the department itself and ruled against Landor, but the Supreme Court agreed to hear the case in June 2025. Oral arguments were held in November. Writing for the majority, Justice Neil Gorsuch said that Arluipa does not apply to individual prison officials, as they had not entered any agreement with the federal government and knowingly consented to answer private suits under Arloepa. Gorsuch suggested

that allowing Landers claim to proceed would give Congress effectively unbridled police power, as it could regulate a private individual's conduct if they received pay from a recipient of federal funds. Mr. Lander's case cannot proceed against them any more than a breach of contract action might proceed against a defendant who never formed a contract, Gorsuch said. The court's three Democratic-appointed justices dissented. Justice Katanji Brown Jackson wrote, Neither respondents nor the court contests Congress's power to impose Arluipa's substantive directive accommodating religious freedom. But the majority adopts a peculiar position that Congress is powerless to create and a state is powerless to accept the natural next step. A damage is remedy against officials who

violate that directive. By insulating individuals from lawsuits, even if they violate the law, she continued, the ruling ensures that prisoners like Lander who suffer violations of their religious freedom in state prisons, no matter how blatant, will often be left remedialess. Today, we'll share perspectives from the left and right on the decision, and then Associate Editor Audrey Moorhead will give her take. We'll be right back after this quick break. All right, first let's start with some agreements. Commentators on both sides agree that Landers' rights were violated and question whether existing law adequately protects religious liberties. All right, let's move on to what the left is saying. The left criticizes the decision for undercutting religious liberty. Some suggest the current court

only supports religious freedom for certain groups. Others say prisoners now have no pathway for recourse if their religious rights are violated. In Slate, Alexis Romero and Mark Joseph Stern called the decision a wrecking ball to a major religious liberty law. Throughout the opinion, the court analogized Congress's spending power to a contract between the federal government and the states. To the majority, every detail of that contract must be knowingly consented to by all parties who might be affected, Romero and Stern said. But Arloipa is legislation, not a contract. So as Jackson wrote, it's doubtful that the Constitution actually requires this unrealistic level of contractual clarity. Moreover, the state officials in this case arguably did agree to be bound by federal law. After all, they signed an employment contract with a prison that receives federal funding by virtue of Arloipa.

State officials are trained on their inmates' rights, and prison litigation has been around for centuries, under Arluipa and other statutes. There's no serious argument that these state officials were blind to the consequences that might come from violating the rights of the prisoners they were in charge of, Romero and Stern said. When Landau tried to vindicate his rights, the Supreme Court didn't just refuse to recognize them. they took the opportunity to issue a sweeping change in constitutional law that risks hobbling a host of important federal protections. In the nation, Elie Mistal argued the Supreme Court loves religious freedom, just not for Rastafarians. Usually, the Supreme Court treats the free exercise clause as if it were written on a Dead Sea scroll, but this case raises the question of whether their religious tolerance extends to only the rights of Christians, Mistal.

Indeed, the way the court squared its normally robust protection of religious freedom, with its decision to allow Landers' rights to be flagrantly violated was to pretend the case wasn't about religion at all. Gorsuch devotes all of one paragraph to the First Amendment violation at the heart of the case. Instead, he cast the whole thing as an examination of Congress's power under the spending clause. Gorsuch argues that employees of institutions that accept federal funds have to agree to be sued under the Arloepa before such lawsuits can proceed, Mistal said. The entire structure of civil rights laws is based on the premise that receiving federal dollars makes you subject to federal rules and consequences. Gorsuch would throw that entire premise into the trash. In his world,

you are only subject to federal civil rights laws if you personally agree to follow them. In Religion News Service, Elizabeth Reiner-Platt said, religious freedom depends on who you are. The opinion authored by Justice Neil Gorsuch held that in order to be subject to suit, prison employees must voluntarily and knowingly consent to answer lawsuits under Arluipa, something employees are unlikely to agree to, Platt wrote. Without any threat of financial punishment, employees of state jails and prisons can trample inmates' religious rights with impunity. And while courts may still order prisons to accommodate incarcerated people's religious beliefs, such as being provided halal meals,

this means little in cases like Landers, when the damage has already been done. This non-financial relief can be avoided, as prisons frequently move in incarcerated people between facilities to evade liability for rights violations. Lander himself was transferred between three different facilities in the course of six months, Platt said. Rather than being a deviation from the Supreme Court's broad view of religious liberty rights, Tuesday's Lander decision is part of a long-standing pattern. While religious liberty claims have been brought and won by people from many different

backgrounds and walks of life, including people in prison, the path is often far harder for those who face obstacles within our larger judicial system. All right, that is it for what the left is saying, which brings us to what the right is saying. The right is mixed with some saying this is an issue for Congress. Many say the case's result shows prisoners do not have the adequate legal remedies for religious freedom violations. Others argue that Landers' religious rights were violated. The Wall Street Journal editorial board argued religious prisoners need Congress's help. Mr. Landers should have been protected by the Religious Land Use and Institutionalized Persons Act.

But what recourse does he have now? No court can restore his hair. He can't sue Louisiana for damages because of sovereign immunity. So we wanted to sue the prison officials personally, the board wrote. Unfortunately for him, that lawsuit has a federalism problem. Under Arluipa, Justice Neil Gorsuch writes, state prison systems that take federal money must agree to not substantially burden religious exercise. Individual prison guards, however, aren't a party to that bargain.

That's if Congress doesn't act. To be sure, Justice Gorsuch says, Mr. Lander and the dissent identify ways in which Congress could have law imposed personal liability, the board said. Is it possible for lawmakers to find that kind of agreement? Arloipa passed in 2000 by unanimous consent, but in these polarized days, Democrats often treat religious liberty as if it's code for right-wing agenda. Mr. Lander's case is evidence it isn't, and Congress can act for religious prisoners of all

faiths. In the Daily Signal, Cully Stimson and Helen Wend suggested the case was decided by a narrow legal question. The issue in the case that made its way to the Supreme Court wasn't whether the officer's conduct was outrageous. It was, Stimson and one wrote. The narrow legal question presented to the Supreme Court was whether appropriate relief under the religious land use and institutionalized persons act may include money damages and suits against government officials in their individual capacities. In this case, the Louisiana's Department of Corrections accepted federal funding and agreed to comply with Arluipa's requirements, but the individual correctional

officers employed by LDOC did not. Because Congress lacks a general power to regulate individuals through the spending clause, the court concluded that personal liability may be imposed only on parties who knowingly and voluntarily consent to the conditions attached to federal funds, Stimson and Wendz said. The dissent said the majority magically transforms a federal statute into an invitation to be accepted or declined, deemed binding only if each particular defendant has explicitly agreed to be penalized. As a result, prison officials will have little incentive to accommodate the free exercise rights of prisoners, knowing full well that if they violate the law, they won't be held personally liable. In the National Catholic Register,

Andrea Pachati Bear said the prison officials shouldn't be able to walk away with no consequences. It is worth setting aside at the outset a concern that opening the courthouse doors to prisoners on religious liberty claims would flood federal courts with frivolous lawsuits. It would not, Pachati Bear wrote. Arloupa does not give prisoners the right to ignore prison rules. officials may restrict or burden religious practice when they can show a compelling reason and when they use the least intrusive means to achieve it. Under the Prison Litigation Reform Act, any prisoner who wants to sue in federal court must first exhaust every available grievance procedure within the prison system. That requirement alone screens out a large share of potential

claims before a judge ever sees them. So the court was never asked to give prisoners a blank check. It was asked something narrower. When an official disregards the law, can he be held personally responsible. Under today's ruling, the answer is no, Chadi Bear said. Congress responded to a 1990 decision that weakened the free exercise clause by passing Arloipa to provide a shield to religious liberties of prisoners. Today's opinion confirms that that shield lacks a corresponding sword when it comes to holding individual officials accountable. All right, let's head over to Audrey for her take. Thanks, John. All right, everybody, I am back for my take. This case has been a genuine head scratcher for me since I first started following it in October.

At first glance, it seemed like a typical religious liberties case. A citizen's rights were most likely violated, but a lack of clarity in the law brought him before the Supreme Court to litigate the minutiae. But the issues at play actually go far deeper. I do want to lay out the one indisputable fact here. Damon Lander suffered an unconscionable and, more importantly in matters of the law, unconstitutional violation of his religious liberties. For months, Lander had been in serving prison time for his crimes, which restricted most of his personal freedoms while protecting his rights, including the right to religious observance. Two government facilities honored those rights without incident before his final prison transfer,

with only three weeks left on his sentence, close enough to freedom to taste it. Then, despite his best efforts to invoke his constitutional and, as he argued, statutory rights, he was forcibly restrained and those rights were violated. And that violation was fundamentally irremediable. No matter how much the law is on Landers' side, the state of Louisiana could not grow Landers' hair back. I'm disturbed by basically every detail of his story, but for some reason I've been especially stuck on the fact that his hair was cut very near the end of his prison sentence. The timing doesn't make the act any more or less wrong, of course, but I can't help but imagine

how being so close to the end of his sentence would sharpen the sting. I don't think anyone who hears his story could honestly say that Lander didn't suffer a grievous injury under the law. I also don't think anyone could say that Lander's case is a one-off. This sort of discrimination could happen to anyone with sincerely held religious beliefs, though the danger is certainly greater for people like Lander. The Rastafari movement in the U.S. is small and ethnically concentrated, leaving people more prone to misunderstanding or disregarding their beliefs.

I think most people would say the religious land use and institutionalized persons act, or Arluipa, was practically designed for people like Lander to have some recourse. and at first I assumed the court would decide unanimously, or nearly so, in his favor. Arluipa is, after all, supposed to give citizens who have their religious liberties violated the ability to sue for redress, but on Tuesday, the Supreme Court ruled that Lander could not sue the prison guards who personally cut off his hair. In Justice Neil Gorsuch's view, writing for the majority, the spending clause of the Constitution limits the law's application. When Congress attaches strings to federal funding, like telling states they must

recognized religious rights and agree to answer lawsuits from individuals in order to receive that funding, the federal government creates a contract between itself and the states. But Congress didn't create a contract with each individual state employee, meaning those employees have not given their voluntary and knowing consent to the law's requirement that they answer lawsuits. In this case, therefore, Gorsuch argues that Arloipa doesn't provide Lander with a method to seek redress from state employees. On first reading, Gorsuch's constitutional logic basically made sense to me, even if it really grates against my religious freedom principles. But Justice Katanji Brown Jackson's emphatic descent through a wrench in the gears, Jackson argues that the majority's reasoning,

and particularly Gorsuch's contract analogy, doesn't hold up. Instead, it separates rights and remedies through a slide of hand. Jackson argues that Arloiba gives Lander the ability to sue the guards for monetary damages, a question that Gorsuch said the court didn't need to answer directly yet. Simply because the court has already interpreted the Religious Freedom Restoration Act, or RFRA, which it has long read as a sister law to Arluipa to allow for monetary damages. Furthermore, Lander should be able to sue the guards because Congress intended for his cause of action, the facts or events on which he can sue, to be valid under the law. And anyway, the law was no secret, so prison guards should be expected to abide by it

even if they don't formally enter into a contract. Thus, in this apparent religious freedom case, the difference between Gorsuch and Jackson isn't over Lander's religious rights and guarantees. It's over federalism and congressional power. Gorsuch argues that allowing lawsuits against state employees without formal contracts under the spending clause would massively expand Congress's regulatory power over individual behavior. Jackson retorts that Congress already has that power. The fundamental split here is between their vastly different views of the law, limits of Congress's authority under the Constitution, a difference consistent with the rest of their jurisprudence. I thought Supreme Court expert Sarah Isker put it well. Gorsuch and the majority are

typically more concerned with limiting federal power, while Jackson and the dissenters are typically more concerned with enhancing citizens' power to seek redress against the government. Having said, all of that, I'll deliver my honest take. I am not sure who's right. I'm a sucker for generalizable principles of law, so Gorsuch's argument for unilateral. treating spending clause power as an affair of contracts and consent is appealing to me. It's a broad principle that could apply to more laws than just Arluipa, and it could protect state employees from being made to behave in discordance with their personal beliefs by an act of Congress.

I imagine that's why Gorsuch reached for culture war examples as potential threats of congressional overreach. On the other hand, I'm solidly with Jackson that citizens like Lander should be able to seek some sort of recourse for their rights violations, and she certainly made a strong case for court precedent being on her side. Being evenly split between their arguments has given me a strange detachment from the case. I find myself in the position of accepting the result basically neutrally, and thinking instead about how redress for religious liberties violations can move forward. It truly frustrates me that Damon Lander himself remains without recourse. But to its credit,

the court did give Congress a roadmap to ensure that future citizens in Lander's position can get justice for the violations of their rights. Congress could require individuals, agents to enter into contracts with the federal government, or it could require states to enact their own laws guaranteeing the ability to seek redress. In either case, the Roberts Court seems to be continuing its established trend of asking Congress to do a better job of making laws. I sincerely hope that Congress takes it up on the challenge. That's it for my take. I'll pass it off to executive editor Isaac Saul for a staff dissent. Thanks so much for listening. Thanks, Audrey. I secure with my dissent today. To draw an imperfect analogy, imagine that Tangle were to receive federal funds from the government. And a condition of those funds was that we follow federal copyright laws. If an editor on my team was caught violating a copyright infringement law, it strikes me as rather absurd to say that employee has not consented to being liable for copyright law,

only Tangle Media LLC has. If the person whose intellectual property we stole was trying to sue my employee, but somehow the outcome across these court rulings produced a situation where they can't sue the employee, me, or Tangle, we'd all feel that something had broken in along the way. The idea that prison guards have not issued voluntary and knowing consent to be sued, if they violate the rights of prisoners, feels even more fraught, what would constitute such consent more than signing an employee contract to work as a guard in a federally funded prison. One almost has to believe the inverse, that the guards didn't know violating the rights of the prisoner in their care

could lead to them being sued. This is fanciful stuff, and I find the court's conclusion both enraging and to be an intentional distortion of the Constitution in order to further limit congressional spending power the religious freedoms of Lander be damned. We'll be right back after this quick break. And now for a deeper look. In 1990, the Supreme Court sided with the state of Oregon

after it denied unemployment benefits to two men who were fired for ingesting peyote, a hallucinogen they said was part of Native American religious ceremonies. The decision in Employment Division, Department of Human Resources of Oregon v. Smith, which held that laws could burden religious expression without violating the First Amendment so long as they were neutral and generally applicable, was widely considered one of the most severe blows. to religious liberties in modern U.S. history. In response, with broad and bipartisan support, Congress passed the Religious Freedom Restoration Act three years later, restoring stronger protections

for religious exercise across all levels of government. However, this restoration of the pre-Smith standard didn't last long. In 1997, four years after the RFRA's passage, the Supreme Court significantly weakened the law. In City of Born v. Flores, Scotis ruled that the RFRA could not be applied to state and local governments, which make decisions concerning common sites of religious expression like state prisons and public schools. The Religious Land Use and Institutionalized Persons Act, the statute at the heart of Lander, was born out of this second setback, using Congress's power of the purse to forbid states that receive federal funds from substantially burdening religious exercise in land use disputes and institutional settings. Rounding out a turbulent

decade for religious liberty protections, Arlouepa unanimously passed a House and Senate by voice vote in 2000, and on September 22nd, President Bill Clinton signed it into law. All right, here's your under-the-radar story for today, folks. On Wednesday, the Washington Post published results from an experiment it ran to test the biases of popular artificial intelligence chatbots, finding that most models appeared to be biased towards the left. Researchers tested the bots, such as OpenAIs chat GPT, Anthropics Claude, XAI's GROC and Google's Gemini, with a series of political questions and with personalization settings turned off. Then a Washington Post reporter analyzed their responses for pronouncing left

and right-leaning views or both. Researchers determined 80% of ChatGPT's responses were exclusively left-leaning, with just 3% bias to the right. Claude's responses were 43% left-leaning, with 0% rated as solely right-leaning. Grok was 40% left and 33% right, and Gemini scored as the most balanced, with 93% of responses considering both sides. The Washington Post has this story, and you can check it out with a link in today's episode description. In this week's The Road Not Taken, our editorial team had close to unanimous decisions on what to cover this week. The Democratic Socialist candidates on Tuesday, the housing bill on Wednesday, and today's Supreme Court's Redlock's case were all decisions that we arrived at naturally, based on the robust commentary we found for each topic.

The court's ruling in an Immigration and Nationality Act case and Kier-Starmers' resignation, nation came close behind our top picks, and you can keep an eye out on our YouTube channel for a video that we're going to be doing about Star Mirror in the coming weeks. That brings us to Monday, which was a choice between two topics we were reluctant to cover, the Iran War and the Reflecting Pool. While updates on U.S. Iran negotiations are obviously important, we had already covered this conflict twice the week before, leading us to focus our commentary on Vice President J.D. Mans' role in peace talks. As for the reflecting pool, which dominated commentary

over the weekend. We balked at providing in-depth commentary to an issue so shallow, excuse the pun. Our compromise was a short segment to lead off our latest episode of Suspension of the Rules, which you can check out on our YouTube channel and your favorite podcast platforms. And last but not least, our have a nice day story. The Galapagos Islands have no post office. Instead, they have a wooden barrel on the island of Floriana, where visitors leave mail and strangers carry it home to hand deliver, a system 18th-century whalers invented and nobody ever stopped using. In May, a man named Hugh knocked on Peter Clist's door in Petersfield, England, handed him a postcard written in Spanish and left. It turned out to be

from a former student of Clists sent from the barrel to her old clas. One traveler, so moved by the tradition, returned to Floriana the following year, collected 55 pieces of mail, and delivered every one. Usually people were initially confused, he wrote, but that would turn to complete joy as they read their letter. Upworthy has this story and you can check it out with a little. link in today's episode description. All right, everybody, that is it for today's episode. As always, if you'd like to support our work, please go to readtangle.com, where you can sign them for

a newsletter membership, podcast membership, or a bundled membership that gets you a discount on both. As was mentioned at the top, we've got a new episode of Suspension of the Rules, where the team wades into the wider implications of Zora Mamdani's kingmaking in New York City, the controversy surrounding Tulsi Gabbard's supposed association with a cult leader,

and a debate about whether Tara Palmeri should have published an interview excerpt a Congress woman asked her to remove. It's a lively and engaging episode, and I highly encourage you to go watch it on YouTube, where you might see me accidentally show up on camera. A little embarrassing, but pretty funny. We'll be back in your ears next week. For Isaac, Audrey, and the rest of the crew, this is John Law signing off. Have an absolutely wonderful weekend, y'all. Peace. Our executive editor and founder is me, Isaac Saul, and our executive producer is John Wall. Today's episode was edited and engineered by Dewey Thomas.

Our editorial staff is led by managing editor Ari Weitzman with senior editor Will Kovac and associate editor, Audrey Moorhead, Lindsay Canuth, and Bailey Saul. Music for the podcast was produced by Diet 75. To run more about Tangle and to sign up for a membership, please visit our website at retangle.com.