Term: 2010
Docket: 08-1438
Harvey Leroy Sossamon, Iii, Petitioner v. Texas Et Al.
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08-1438 SOSSAMON V. TEXAS DECISION BELOW: 560 F.3d 316 LIMITED TO THE FOLLOWING QUESTION: “WHETHER AN INDIVIDUAL MAY SUE A STATE OR STATE OFFICIAL IN HIS OFFICIAL CAPACITY FOR DAMAGES FOR VIOLATIONS OF THE RELIGIOUS LAND USE AND INSTITUTIONALIZED PERSONS ACT, 42 U.S.C. §2000cc ET SEQ. (2000 ED.).” JUSTICE KAGAN TOOK NO PART CERT. GRANTED 5/24/2010 QUESTION PRESENTED: The Religious Land Use and Institutionalized Persons Act, 42 U.S.C. §§ 2000cc to 2000cc-5, provides an express private right of action to "obtain appropriate relief against a government," id. § 2000cc-2. The statute defines "government" to include state and local governmental entities and any "official of [such] an entity." Id § 2000cc-5(4) (A). The Fifth Circuit held, in conflict with the decisions of other courts, that the Constitution prohibits Congress from authorizing damages claims against states, or against state officials in their individual or personal capacities, for violations of the statute. The question presented is: Whether states and state officials may be subject to suit for damages for violations of the Religious Land Use and Institutionalized Persons Act? LOWER COURT CASE NUMBER: 07-50632
In the case of Harvey Leroy Sossamon III v. Texas et al., 2010, Sossamon, a prisoner in Texas, sued the state and prison officials under the Religious Land Use and Institutionalized Persons Act (RLUIPA), claiming that his religious freedoms were violated by denying him access to a prison chapel for worship and use of the prison's dormitory for religious study. The Supreme Court ruled against Sossamon in an unanimous decision stating that states do not consent to waive their sovereign immunity to private suits for damages under RLUIPA. Sovereign immunity refers to a legal doctrine holding that states cannot commit legal wrongs and are immune from civil suits or criminal prosecution; this principle was upheld by the court as it found no clear indication within RLUIPA’s text suggesting Congress intended such waiver. Therefore, while prisoners can bring actions against individual officers responsible for alleged violations of their rights under RLUIPA, they cannot sue state governments or agencies directly.
In the dissenting opinion for Harvey Leroy Sossamon III v. Texas et al., Justice Stephen Breyer, joined by Justices Ruth Bader Ginsburg and Sonia Sotomayor, argued that Congress clearly intended to allow damages as a remedy when it passed the Religious Land Use and Institutionalized Persons Act (RLUIPA). They disagreed with the majority's interpretation of "appropriate relief" in RLUIPA as excluding monetary damages against states. The dissenting justices believed this interpretation was inconsistent with precedent and undermined RLUIPA's purpose of protecting religious freedom rights of institutionalized persons. They contended that if Congress wanted to exclude such an important form of relief, they would have done so explicitly rather than leaving it ambiguous. Therefore, they concluded that prisoners like Mr. Sossamon should be able to sue state officials for monetary damages under RLUIPA when their religious freedoms are violated.
