Background
Damon Landor, a Rastafarian, was transferred between Louisiana state prison facilities in 2020. His faith required him to keep his hair uncut. Before arrival at the receiving facility, he provided intake officers with a copy of Ware v. LDOC, 866 F.3d 263 (5th Cir. 2017), which held that RLUIPA generally bars prisons from cutting Rastafarian inmates’ hair. According to Landor, the officers discarded the case and shaved his head anyway, causing him to violate his religious beliefs.
Landor sued the Louisiana Department of Corrections (LDOC) and the individual officers in their personal capacities under the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), seeking money damages. The district court dismissed all RLUIPA claims. On appeal, Landor contested only the dismissal of the personal-capacity claims against the individual officers. The Fifth Circuit affirmed, holding that RLUIPA does not permit suits against officers in their individual capacities. The Supreme Court granted certiorari.
RLUIPA was enacted under Congress’s Spending Clause authority. As a condition of receiving federal funds, state prison systems must agree not to impose substantial burdens on prisoners’ religious exercise and must consent to private lawsuits alleging violations. LDOC did not dispute that it accepted these conditions. The question before the Court was whether the individual officers — who entered no such agreement — could nonetheless be personally sued for damages.
The Court’s Holding
In a 6-3 opinion authored by Justice Gorsuch and joined by the Chief Justice and Justices Thomas, Alito, Kavanaugh, and Barrett, the Court affirmed the Fifth Circuit. The Court held that individuals may not be held personally liable under a Spending Clause statute unless they have voluntarily and knowingly consented to answer lawsuits under that statute. Because the individual officers never entered any agreement with the federal government, they cannot be defendants under RLUIPA — just as a party who never signed a contract cannot be sued for breach of it.
The Court grounded its analysis in the foundational principle that the Spending Clause does not empower Congress to regulate conduct directly; it allows Congress only to attach conditions to the funds it distributes. Beyond termination of funds, any additional sanction — including exposure to private damages suits — requires the voluntary and knowing consent of those who must bear it. The “contract analogy” the Court has employed since at least 1845 serves to ensure that spending conditions bind only those who genuinely agreed to them.
The Court rejected all of Landor’s counterarguments. Agency law does not make employees personally liable for their employer’s contractual undertakings. South Dakota v. Dole‘s four-part test supplements — it does not displace — the consent requirement. The fact that the officers receive paychecks partially funded by federal dollars does not constitute knowing and voluntary consent; accepting that theory would give Congress an effectively unlimited police power to regulate any individual touched, however indirectly, by federal spending. Justice Jackson dissented, joined by Justices Sotomayor and Kagan.
Key Takeaways
- RLUIPA does not authorize personal-capacity damages suits against individual state prison employees who have not themselves agreed to answer such claims with the federal government.
- Under the Spending Clause, Congress may impose sanctions beyond fund termination only on entities or individuals who voluntarily and knowingly consent; Congress cannot regulate nonconsenting parties directly, regardless of how RLUIPA’s policy goals might be served.
- Agency principles do not extend a principal’s contractual consent to its employees; an employer’s agreement to face RLUIPA suits does not bind individual officers to personal liability.
- Receiving a paycheck that ultimately traces back to federal funding is not a form of implicit consent to Spending Clause liability — adopting that theory would functionally transform the Spending Clause into an unrestricted federal police power.
- Landor may still have available remedies: the Court noted that a state-law cause of action in state court may remain viable, and Congress or Louisiana could separately legislate to create personal-liability exposure going forward.
Why It Matters
This decision significantly narrows the practical reach of RLUIPA for incarcerated plaintiffs seeking money damages. By confirming that personal-capacity liability under Spending Clause statutes requires the individual defendant’s own consent, the Court effectively forecloses a major avenue for damages relief — leaving prisoners who suffer religious-liberty violations to pursue suits against the institution itself (subject to sovereign immunity constraints) or seek injunctive and declaratory relief rather than compensation from the officers who carried out the violation.
More broadly, the ruling reinforces the structural limits on Congress’s Spending Clause authority at a moment when the Court has been actively policing the boundaries between spending conditions and direct federal regulation. The majority’s refusal to treat indirect federal-fund recipients as having impliedly consented to regulation signals that lower courts and Congress must scrutinize carefully whether each tier of a funding relationship has actually agreed to be bound — a constraint with implications well beyond the prison context, touching any federal grant program that purports to impose obligations on employees or contractors of fund recipients.