Landor v. Louisiana Department of Corrections and Public Safety

Questions presented

SCOTUS records, cert granted 23 Jun 2025

Congress has enacted two "sister" statutes to protect religious exercise: the Religious Freedom Restoration Act of 1993 (RFRA), 42 U.S.C. 2000bb et seq., and the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), 42 U.S.C. 2000cc et seq. In Tanzin v. Tanvir, 592 U.S. 43 (2020), this Court held that an individual may sue a government official in his individual capacity for damages for violations of RFRA. RLUIPA's relevant language is identical. The question presented is whether an individual may sue a government official in his individual capacity for damages for violations of RLUIPA.

Opinion summary

Etalia.ai summary of the majority opinion

The Court held that RLUIPA does not allow damages suits against state prison employees in their personal capacities when those employees did not voluntarily and knowingly agree to be bound. Writing for the Court, Justice Gorsuch explained that Congress’s Spending Clause power lets it place conditions on federal funds, but additional sanctions require consent. Louisiana’s prison system agreed to the RLUIPA funding conditions, but the individual officers did not. The Court rejected arguments based on agency law, South Dakota v. Dole, indirect receipt of federal funds through paychecks, and the Necessary and Proper Clause. It affirmed the dismissal of Damon Landor’s claim against the officers.

Dissent summary

Etalia.ai summary of the dissenting opinions

Justice Jackson, joined by Justice Sotomayor and Justice Kagan, dissented. The dissent argued that Congress enacted RLUIPA as a law, not a contract, and that the statute itself authorizes prisoners to sue offending prison employees in their individual capacities for appropriate relief. It said the majority wrongly turned Spending Clause legislation into a private agreement requiring each defendant’s personal consent. The dissent also argued that precedent allows Congress to use its spending power and the Necessary and Proper Clause to regulate conduct needed to make federal programs effective, including imposing liability on state officials who violate federal conditions.