SCOTUS: Landor v Louisiana Department of Corrections Rules on Federalism, Not Religion

• The Supreme Court's recent term concluded with *Landor v. Louisiana Department of Corrections*, a case argued in November but decided in late June.
• Despite involving a Rastafarian prisoner, the *Landor* decision ultimately focused on federalism and funding, rather than religious liberty.
• Many observers, including the author, had anticipated a straightforward, unanimous victory for the prisoner in the *Landor* case.
• This outcome diverged from recent Supreme Court terms, which often concluded with significant religious freedom rulings like *Fulton*, *Kennedy*, and *Mahmoud*.
• Past religious liberty cases included *Fulton v. City of Philadelphia* (2021) affirming adoption services claims and *Kennedy v. Bremerton School District* (2022) abandoning the "Lemon test."

Ultimately, the Court's ruling in *Landor v. Louisiana Department of Corrections* diverged from expectations, focusing predominantly on principles of federalism and funding, rather than the religious liberty claims of the Rastafarian prisoner involved.

The Supreme Court's annual late June conclusion to its term has frequently been characterized by a flurry of high-profile decisions, often including significant cases related to church-state separation or religious freedom. For instance, the 2021 term saw a unanimous Court affirm a religious freedom claim concerning adoption services in *Fulton v. City of Philadelphia*. The following year, *Kennedy v. Bremerton School District*, widely known as the "praying-football-coach case," marked the justices' declaration that they had previously abandoned the controversial "Lemon test." Last year, the Court's decision in *Mahmoud v. Taylor* on the final day of the term revitalized the 1972 precedent set in *Wisconsin v. Yoder*, which established parents' fundamental right to guide their children's religious education and upbringing.

However, the most recent term presented a notable deviation from this pattern, particularly concerning its sole religious liberty case. While the ruling in *Landor v. Louisiana Department of Corrections* was indeed released in late June, its substance proved to be quite different from the religious freedom disputes that have recently dominated headlines.

The *Landor v. Louisiana Department of Corrections* case, which involved a Rastafarian prisoner, was argued before the Supreme Court in November. Despite the early argument date, the decision was not handed down until late June, a delay that surprised many court observers. The prevailing expectation, shared by numerous commentators including the author of the original analysis, was that the case would result in a straightforward, unanimous victory for the prisoner.

Ultimately, the Court's ruling in *Landor v. Louisiana Department of Corrections* diverged from expectations, focusing predominantly on principles of federalism and funding, rather than the religious liberty claims of the Rastafarian prisoner involved. This outcome repositioned the case from an anticipated landmark religious freedom ruling to one primarily addressing the intricate financial and jurisdictional relationships between state and federal entities.

The Supreme Court has a recent history of engaging deeply with religious liberty questions, often leading to significant shifts in legal doctrine. In *Fulton v. City of Philadelphia*, for example, while the Court unanimously sided with a religious freedom claim regarding adoption services, three concurring justices voiced considerable frustration over the Court's reluctance to reconsider or repudiate its long-standing *Smith* doctrine. This illustrates the ongoing tension and debate within the Court regarding the scope of religious protections.

Similarly, the 2022 *Kennedy v. Bremerton School District* decision was notable not just for its outcome in favor of a football coach's prayer, but for the Court's explicit statement that it had "long ago abandoned" the "Lemon test," a framework previously used to evaluate Establishment Clause cases. These cases, alongside *Mahmoud v. Taylor* which affirmed parental rights in religious education, underscore a trend of the Court actively shaping religious liberty jurisprudence. Against this backdrop, *Landor*'s ultimate focus on federalism and funding, rather than faith, marks a distinct turn for a case initially perceived through a religious freedom lens.

The unexpected emphasis on federalism and funding in *Landor v. Louisiana Department of Corrections* establishes a significant precedent that extends beyond the immediate facts of the case. By centering its decision on these structural issues, the Supreme Court has provided guidance that could influence a wide array of future legal challenges. This includes litigation involving state correctional departments, where federal mandates or funding mechanisms intersect with state autonomy, as well as other disputes concerning the financial interplay between state and federal governments.

This particular framing of the *Landor* decision suggests that lawyers and legal scholars should view it primarily through the lens of state-federal financial and jurisdictional dynamics. Its implications are likely to be felt more acutely in areas concerning governmental funding, state sovereignty, and the enforcement of federal regulations within state institutions, rather than in the evolving landscape of religious freedom law.

Lawyers should understand that *Landor v. Louisiana Department of Corrections* primarily establishes precedent on federalism and funding, rather than religious liberty, which could influence litigation involving state correctional departments or similar state-federal financial disputes.

Source: Reporting based on legal commentary.