Why It Matters

A recent CRS report examines the Supreme Court's decision in Landor v. Louisiana Department of Corrections and Public Safety, which significantly constrains how Congress can enforce religious liberty protections against state officials.

The Big Picture

The case centered on a Rastafarian former prisoner of the Louisiana Department of Corrections who wanted to observe his religious obligation to leave his hair uncut. Two of Louisiana's prisons accommodated his request, but when officials at another facility forcibly shaved his head, he sued for damages under the Religious Land Use and Institutionalized Persons Act (RLUIPA). The plaintiff sought declaratory and injunctive relief as well as money damages from prison officials in their individual capacities.

RLUIPA, enacted by Congress in response to Supreme Court limitations on the Religious Freedom Restoration Act (RFRA), relies on Congress's Commerce Clause and Spending Clause authority. The statute bars prisons that accept federal funds from substantially burdening religious observance unless the state can show the burden is the least religion-restrictive means to further a compelling governmental interest. In 2015, the Supreme Court ruled that RLUIPA required an exemption from a prison grooming policy for a prisoner who sought to wear a beard for religious reasons.

The Landor plaintiff's case took a different turn. After his release from prison in January 2021, the district court ruled that his claims for declaratory and injunctive relief were moot. The court also dismissed his individual-capacity RLUIPA claims for damages against the prison officials. The Fifth Circuit affirmed, holding that RLUIPA does not permit lawsuits for money damages against officials in their individual capacities.

The Bottom Line

The Supreme Court's majority, led by Justice Gorsuch and joined by Chief Justice Roberts and Justices Thomas, Alito, Kavanaugh, and Barrett, held that individuals cannot be held liable in their personal capacities under a Spending Clause statute when they did not personally consent to its conditions. The decision means Congress cannot impose liability on individual state employees through spending-based legislation without those employees' knowing and voluntary agreement to comply with funding conditions, even if their employer accepted federal dollars. This principle applies regardless of whether an employee's paycheck includes federal funds. For prisoners alleging religious discrimination in state facilities, the practical effect is that individual officials may face no personal liability, though the facilities themselves remain subject to federal oversight.

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