Landor v. Louisiana Department of Corrections and Public Safety
Question presented
Whether an individual may sue a government official in his individual capacity for damages for violations of the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), 42 U.S.C. § 2000cc et seq.
Background
Damon Landor, a Rastafarian who had not cut his hair for nearly twenty years, was held down and shaved by Louisiana prison officials weeks before the completion of a five-month sentence at a federally-funded state correctional facility — over his presentation of a Fifth Circuit opinion holding that Louisiana's hair-cutting policy violates RLUIPA. Everyone agrees a RLUIPA violation occurred. The question is whether RLUIPA's authorization of 'appropriate relief against a government,' 42 U.S.C. § 2000cc-2(a), authorizes private suit for money damages against state officers in their individual capacities. The Fifth Circuit held that 'although RLUIPA's text suggests a damages remedy, recognizing as much would run afoul of the Spending Clause,' affirming dismissal under Sossamon v. Lone Star State of Texas, 560 F.3d 316 (5th Cir. 2009). Six judges, in two opinions, would have granted rehearing en banc. The Supreme Court granted certiorari and the United States, reversing its prior position, supported petitioner.
Procedural posture
- Argued
- November 10, 2025
- Decided
- Pending
- Tenth Seat opinion published
- May 14, 2026
- Term
- OT 2025
The Tenth Seat
- Opinion of the Courtread →
Reverse and remand. (1) RLUIPA's text authorizes a private suit for money damages against a state official acting under color of state law in his individual capacity, on the same textual analysis Tanzin v. Tanvir, 592 U.S. 43 (2020), applied to RFRA's identical operative language. (2) Money damages are 'appropriate relief' in such a suit; Sossamon v. Texas, 563 U.S. 277 (2011), turned on the defendant being a sovereign, an obstacle not present here. (3) The remedy is within Congress's constitutional authority: the defendants stand in materially the same position as the state-officer defendant in Salinas v. United States, 522 U.S. 52 (1997), and the case falls inside the outer limit Sabri v. United States, 541 U.S. 600 (2004), set on Necessary-and-Proper authority to reach non-recipients of federal funds.
- Dissentread →
Affirm. RFRA and RLUIPA share operative text but not constitutional source; Tanzin's analysis does not transfer because Spending Clause legislation derives its legitimacy from the recipient's knowing acceptance of the bargain. Twenty-five years of unanimous appellate decisions denying individual-capacity RLUIPA damages reflect that no funding recipient could have understood 'appropriate relief' to subject its officers — non-parties to the federal-state agreement — to personal damages liability, per Cummings v. Premier Rehab Keller, 596 U.S. 212 (2022). The Salinas/Sabri/Dixson line is anti-corruption Necessary-and-Proper precedent confined by this Court's own subsequent decisions in Kelly, Snyder, and Ciminelli; it does not extend to civil violations of substantive program conditions against non-recipient state officers.
- Sources & Verificationread →
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- Comparison with the Court’s decisionPending decision
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