Landor v. Louisiana Dept of Corrections and Public Safety
The Court holds that individuals may not be held personally liable under a Spending Clause statute unless they have voluntarily and knowingly consented to answer lawsuits under it. Because the individual prison officers sued here never entered any agreement with the federal government to face liability under the Religious Land Use and Institutionalized Persons Act, the suit against them in their personal capacities cannot proceed.
Case background
The Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA) was enacted under Congress’s Spending Clause authority and imposes various conditions on federal funds distributed to state prison systems like the Louisiana Department of Corrections (LDOC). One condition requires state prison systems to agree to answer federal suits by private plaintiffs alleging certain substantial burdens on their religious exercises. Damon Landor is a Rastafarian whose religious convictions require him to leave his hair uncut. He alleges that LDOC officers, despite being aware of his religious beliefs, forcibly shaved his head. Relying on RLUIPA, Mr. Landor sued LDOC as well as several of the prison system’s individual officers in their personal capacities, seeking damages from them. The officers moved to dismiss, arguing that while their employer LDOC may have agreed to answer certain private suits under RLUIPA, they were not parties to any such agreement and so could not be sued. The district court dismissed Mr. Landor’s RLUIPA claims against both LDOC and the officers. On appeal, Mr. Landor challenged only the dismissal of his claim against the individual officers, and the Fifth Circuit declined to revive it, holding that RLUIPA does not permit suits against officers in their individual capacities.
Questions Presented
(1) Whether an individual may sue a government official in his individual capacity for damages for violations of RLUIPA.
Holding
Individuals may not be held liable in their personal capacities under a Spending Clause statute unless those individuals have voluntarily and knowingly consented to answer lawsuits under the statute. Because the individual defendants in this case did not voluntarily and knowingly consent to face RLUIPA liability in an agreement with the federal government, Mr. Landor’s case cannot proceed against them. The judgment of the Fifth Circuit is affirmed.
The Court
Justice Gorsuch delivered the opinion of the Court, in which Chief Justice Roberts and Justices Thomas, Alito, Kavanaugh, and Barrett joined. Justice Jackson filed a dissenting opinion, in which Justices Sotomayor and Kagan joined.
What this episode contains
This episode is an AI-narrated reading of the majority opinion in Landor v. Louisiana Dept of Corrections and Public Safety, written by Justice Gorsuch.
AI disclosure: The voice in this episode is AI-generated, using a machine learning model styled to loosely resemble the authoring justice. Tone, inflection, pacing, and emphasis are artifacts of the model and should not be attributed to Justice Gorsuch. The text being read is the Court’s published majority opinion, lightly adapted to improve readability for the spoken format.