Landor v. Louisiana Dept of Corrections and Public Safety

Summary

The Court, in an opinion by Justice Gorsuch joined by Chief Justice Roberts and Justices Thomas, Alito, Kavanaugh, and Barrett, held that RLUIPA cannot impose personal-capacity liability on state prison employees who have not knowingly and voluntarily agreed to answer suits under its Spending Clause provisions. Neither employment by a federal funding recipient nor indirect receipt of federal money establishes the required consent. The Necessary and Proper Clause does not authorize the proposed liability merely because it would advance RLUIPA’s religious-liberty policy. The Court affirmed without deciding whether RLUIPA ever authorizes money damages. Justice Jackson dissented, joined by Justices Sotomayor and Kagan. She concluded that RLUIPA expressly authorizes individual-capacity damages actions and that the Spending and Necessary and Proper Clauses permit Congress to enforce funding conditions against recipient institutions’ employees without their separate consent.