Happy Thursday. This is Associate Editor Audrey Moorehead, 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’ll be writing about an under-the-radar case the Tangle team has been watching 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 for 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 roundup of the stories we didn’t cover. It’s a 15-minute read, so settle in.

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. It’s a lively episode worth your time:

Quick hits.

1. BREAKING: The Supreme Court ruled 6–3 that the Trump administration can remove temporary protected status (TPS) for Haitian and Syrian ​immigrants, allowing them to be deported. (The decision) In a separate 6–3 decision, the Court ruled that the administration can turn away asylum-seekers before they cross the southern border into the United States. (The ruling)
2. 7.2-magnitude and 7.5-magnitude earthquakes struck Caracas, Venezuela, killing at least 164 people and injuring 971 as of Thursday morning; the death toll is expected to rise as the emergency response continues. (The earthquakes)
3. The Commerce Department reported that the personal consumption expenditures price index rose 4.1% on an annual basis in May, the highest rate of increase since April 2023, while core inflation (excluding food and energy prices) rose 3.4%. Inflation rose 0.4% on a monthly basis. (The numbers)
4. The Trump administration requested $87.6 billion in supplemental funding from Congress, primarily for costs related to the Iran war. (The request)
5. 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. (The ruling)
6. Postmaster General David Steiner testified at a Senate committee hearing that, under a proposed Trump administration rule, the Postal Service will not deliver mail-in ballots in states that do not share voter data with the federal government. (The testimony)

Today’s topic.

Landor v. Louisiana Department of Corrections. 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. 

Back up: In 2020, Landor was transferred to Raymond Laborde Correctional Center in Louisiana while serving a five-month sentence for drug possession. As a member of Rastafari, a religion originating in Jamaica in which maintaining dreadlocks fulfills a religious vow, Landor 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 RLUIPA 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 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 RLUIPA 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 RLUIPA.” Gorsuch suggested that allowing Landor’s 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. Landor’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 Ketanji Brown Jackson wrote, “Neither respondents nor the Court contests Congress’s power to impose RLUIPA’s substantive directive accommodating religious freedom… [but the majority] adopts the peculiar position that Congress is powerless to create, and a State is powerless to accept, the natural next step: a damages 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 Landor who suffer violations of their religious freedom in state prisons — no matter how blatant — will often be left remediless.”

Today, we’ll share perspectives from the left and right on the decision, followed by Associate Editor Audrey Moorehead’s take.

Agreed.

• Commentators on both sides agree that Landor’s rights were violated and question whether existing law adequately protects religious liberties.

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’ 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 wrote. “But RLUIPA 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 RLUIPA. 

“State officials are trained on their inmates’ rights, and prison litigation has been around for centuries, under RLUIPA 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’re in charge of,” Romero and Stern said. “When [Landor] tried to vindicate his rights, the Supreme Court didn’t just refuse to recognize them, but took the opportunity to issue a sweeping change in constitutional law that risks hobbling a host of important federal protections.” 

In The Nation, Elie Mystal argued “the Supreme Court loves religious freedom — just not for Rastafarians.”

“Usually, the Supreme Court treats the Free Exercise Clause as if it was written on a dead sea scroll… But this case raises the question of whether their religious tolerance extends only to the right kinds of Christians,” Mystal wrote. “Indeed, the way the court squared its normally robust protection of religious freedom with its decision to allow Landor’s 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 casts 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 RLUIPA before such lawsuits can proceed,” Mystal 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’ RLUIPA — 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 by providing halal meals — this means little in cases like Landor’s, when the damage has already been done.”

“Even this nonfinancial relief can be avoided, as prisons frequently move incarcerated people between facilities to evade liability for rights violations. Landor 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 Landor 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.”

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 adequate legal remedies for religious freedom violations. 
• Others argue that Landor’s religious rights were violated.

The Wall Street Journal editorial board argued “religious prisoners need Congress’s help.”

“Mr. Landor should have been protected by the Religious Land Use and Institutionalized Persons Act (RLUIPA). 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 he wanted to sue the prison officials personally,” the board wrote. “Unfortunately for him, that lawsuit has a federalism problem… Under RLUIPA, Justice Neil Gorsuch writes, state prison systems that take federal money must agree not to 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. Landor and the dissent identify ways in which Congress could have lawfully imposed personal liability,’” the board said. “Is it possible for lawmakers to find that kind of agreement? RLUIPA 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. Landor’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 Nguyen 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 officers’ conduct was outrageous — it was,” Stimson and Nguyen 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 in 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 RLUIPA’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 Nguyen 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 Picciotti-Bayer 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,” Picciotti-Bayer wrote. “[RLUIPA] 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 being asked something narrower: When an official disregards the law, can he be held personally responsible? Under today’s ruling, the answer is No,” Picciotti-Bayer said. “Congress responded [to a 1990 decision that weakened the Free Exercise Clause] by passing RLUIPA to provide a shield to the religious liberties of prisoners. Today’s opinion confirms that that shield lacks a corresponding sword when it comes to holding individual officials accountable.”

My take.

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• Landor’s religious rights were clearly violated, which no one involved with this case disputes.
• Redressing his harm nonetheless sets up a surprising paradox between the extent of Congress’s authority and individual rights.
• I’m truly torn between the majority and minority opinions on this case, and I sincerely hope Congress will act to settle any future issues.

Associate Editor Audrey Moorehead: 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 go far deeper.

I want to lay out the one indisputable fact here: Damon Landor suffered an unconscionable and — more importantly, in matters of law — unconstitutional violation of his religious liberties. For months, Landor had been 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 Landor’s side, the state of Louisiana could not grow Landor’s 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 that story could honestly say that Landor didn’t suffer a grievous injury under the law. I also don’t think anyone could say that Landor’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 Landor: 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 that the Religious Land Use and Institutionalized Persons Act (RLUIPA) was practically designed for people like Landor to have some recourse, and at first, I assumed the Court would decide unanimously (or nearly so) in his favor.

RLUIPA is supposed to give citizens who have their religious liberties violated the ability to sue for redress, but on Tuesday, the Supreme Court ruled that Landor could not sue the prison guards who personally cut off his hair. In Justice Neil Gorsuch’s view, the Spending Clause of the Constitution limits the law’s application: When Congress attaches strings to federal funding — like telling states they must recognize religious rights and agree to answer lawsuits from individuals in order to receive it — it creates a contract between the federal government and the states. But Congress doesn’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, Gorsuch argues, RLUIPA doesn’t provide Landor with a method to seek redress from state employees.

On first reading, Gorsuch’s constitutional logic basically made sense to me, even if it grates against my religious-freedom principles. But Justice Ketanji Brown Jackson’s emphatic dissent threw 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 “sleight of hand.” Jackson argues that RLUIPA gives Landor 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 (RFRA), which it has long read as a “sister law,” to allow for them. Furthermore, Landor 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 “is 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 Landor’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 limits of Congress’s authority under the Constitution, a difference consistent with the rest of their jurisprudence. I thought SCOTUS expert Sarah Isgur 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 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 unilaterally treating Spending Clause power as an affair of contracts and consent is appealing. It’s a broad principle that could apply to more laws than just RLUIPA, 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 overreach.) 

On the other hand, I’m solidly with Jackson that citizens like Landor 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 Landor himself remains without recourse. But, to its credit, the Court did give Congress a roadmap to ensure that future citizens in Landor’s position can get justice for the violations of their rights. Congress could require individual 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.

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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, and with broad, bipartisan support, Congress passed the Religious Freedom Restoration Act (RFRA) 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 Boerne v. Flores, SCOTUS 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 (RLUIPA), the statute at the heart of Landor, 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, RLUIPA unanimously passed the House and Senate by voice vote in 2000, and on September 22, President Bill Clinton signed it into law.

Under the radar.

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 appear to be biased towards the left. Researchers tested the bots — such as OpenAI’s ChatGPT, Anthropic’s Claude, xAI’s Grok, 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% biased 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. You can read more about the results (and specific questions chatbots were asked) in The Washington Post. 

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 dreadlocks 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 Keir Starmer’s resignation came close behind our top picks (keep an eye out for a YouTube video about Starmer 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 the conflict twice the week before, leading us to focus our commentary on Vice President JD Vance’s 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 Suspension of the Rules (which you can watch here).

The extras.

• One year ago today we covered Zohran Mamdani winning New York City’s Democratic mayoral primary.
• The most clicked link in our last regular newsletter was the drownings in France.
• Nothing to do with politics: Why mosquitoes bite some people more than others.
• Our last survey: 1,697 readers responded to our survey asking about the 21st Century ROAD to Housing Act with 39% saying they support the legislation. “This bill should assist my state, California, to address its housing crisis that my Democratic Party has done little to mitigate over the last decade,” one respondent said. “No housing shortage but certainly need to eliminate bureaucratic regulations for construction,” said another.

Have a nice day.

The Galápagos Islands have no post office. Instead, they have a wooden barrel on the island of Floreana, 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 Clist’s, sent from the barrel to her old class. One traveler so moved by the tradition returned to Floreana 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 the story.