The question
Whether a prisoner may sue individual government officials for money damages under the Religious Land Use and Institutionalized Persons Act when they violate his religious rights.
Landor v. Louisiana Dept of Corrections and Public Safety
What the Court decided
The Court limited when prison officials can be sued personally for money damages under the religious-rights law RLUIPA. It held that individuals cannot be held liable in their personal capacities under a Spending Clause statute like RLUIPA unless they voluntarily and knowingly agreed to answer such suits, and because the officials here had not, the damages claim could not proceed against them personally.
How the justices split
6-3The Court's opinion
Gorsuch, joined by Roberts, Thomas, Alito, Kavanaugh, Barrett
RLUIPA rests on Congress's spending power: it conditions federal funds on a state's promise to respect religious exercise. That kind of statute binds the funded institution, not the individual officials personally, unless an official knowingly agreed to be personally liable. Because these officials made no such agreement, they cannot be sued for damages in their personal capacities.
Dissenting
Jackson, joined by Sotomayor, Kagan
The dissent argued the ruling leaves prisoners whose religious rights are violated with no meaningful remedy, because a suit against the institution alone often cannot make them whole, and that Congress meant RLUIPA to be enforceable against the officials who actually commit the violation.
How we know · 3 sourced claims
The Court held individuals may not be held personally liable under a Spending Clause statute like RLUIPA absent their voluntary, knowing consent.
Source: syllabus, Held, at 23-1197
Because the officials had not so consented, the personal-capacity damages claim could not proceed.
Source: syllabus
Gorsuch, J., wrote for the Court; Jackson, J., dissented, joined by Sotomayor and Kagan, JJ.
Source: syllabus, lineup