Supreme Court of the United States

Harvey Leroy Sossamon, Iii v. Texas

April 20, 2011179 L. Ed. 2d 700

Summary

The Supreme Court held that States, by accepting federal funds, do not consent to waive their sovereign immunity to private suits for money damages under the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), so sovereign immunity bars petitioner's damages claim against Texas. Applying the stringent clear-statement rules governing sovereign-immunity waivers, the Court strictly construed RLUIPA's open-ended “appropriate relief against a government” phrase in favor of the sovereign, rejected the argument that Spending Clause legislation operates as a contract carrying an implied damages remedy, and held under the ejusdem generis principle that RLUIPA § 3—which prohibits “substantial burden[s]” on religious exercise rather than “discrimination”—does not fall within § 1003 of the Rehabilitation Act Amendments' residual waiver clause. The judgment of the Fifth Circuit was affirmed. Justice Sotomayor, joined by Justice Breyer, dissented, contending that “appropriate relief” unambiguously includes monetary damages under general remedies principles and the Franklin/Barnes line, and that the majority's reading strips institutionalized persons of meaningful redress.

Holding

  • Whether RLUIPA's authorization of “appropriate relief against a government,” § 2000cc-2(a), constitutes the unequivocal expression of state consent required to waive sovereign immunity to private suits for money damages when tied to the receipt of federal financial assistance.. No. “Appropriate relief” is open-ended and ambiguous about what types of relief it includes; strictly construed in favor of the sovereign, it does not unambiguously waive state sovereign immunity to damages suits, so States accepting federal funds have not consented to RLUIPA damages liability.
  • Whether Spending Clause legislation, operating as a contract, necessarily puts States on notice that damages are always available for breach, such that every Spending Clause enactment satisfies the unequivocal-waiver rule regardless of its text.. No. The Court has not implied that suits under Spending Clause legislation are suits in contract or that contract-law principles apply to all issues they raise; ordinary contract principles fit poorly because contracts with a sovereign traditionally confer no right of action for damages, and implied contract remedies cannot be squared with the longstanding rule that a waiver must be expressly and unequivocally stated in the statute's text.
  • Whether § 1003 of the Rehabilitation Act Amendments of 1986 (42 U.S.C. § 2000d-7) independently waives state sovereign immunity to RLUIPA § 3 damages suits through its residual clause covering “any other Federal statute prohibiting discrimination by recipients of Federal financial assistance.”. No. Even assuming a residual clause could constitute an unequivocal textual waiver, RLUIPA § 3 is not unequivocally a “statute prohibiting discrimination” within the meaning of § 1003: its text prohibits “substantial burden[s]” on religious exercise, not discrimination, and under ejusdem generis the residual clause—whose enumerated statutes all expressly prohibit discrimination—does not clearly extend to § 3.

Docket No. 08-1438

Cited authorities

Read full opinionPDF