The Supreme Court’s decision in Landor v. Louisiana Department of Corrections and Public Safety asks how far a federal promise to protect prisoners’ religious practices really extends. The Court held that the statute at issue can bind a state prison system that accepts federal money, but that it does not, when it operates under the Spending Clause, require individual guards to pay money damages for violating it.
Locked Up, Locks Off
Damon Landor is a Rastafarian whose faith requires him to keep his hair in long locks. While serving a short sentence in Louisiana’s prisons, he was transferred to a facility where, he says, officers ignored his explanation of his beliefs, handcuffed him to a chair, and shaved his head.
So, Landor sued under the Religious Land Use and Institutionalized Persons Act (RLUIPA), a federal law that protects religious exercise in prisons and jails when states accept certain federal funds. Under RLUIPA, a state that takes that money agrees not to place a substantial, unnecessary burden on prisoners’ religious practices and allows prisoners to go to court for “appropriate relief” if their rights are violated.
Landor sought money damages under RLUIPA from both the Louisiana Department of Corrections (LDOC) and the individual officers. Because he had already been released, the courts treated his request for orders regarding future treatment as moot, and his RLUIPA claim against LDOC dropped on appeal.
Broad Statute to Narrow Question
By the time the case reached the Supreme Court, the only RLUIPA question left was whether he could recover money from the officers in their personal capacities.
To answer that, the Court focused on how RLUIPA operates under the Constitution. As applied to state prisons, RLUIPA relies on Congress’s power to spend federal funds and attach conditions, rather than a general power to regulate everyone directly. The majority described this kind of spending scheme as “contract‑like”: Congress offers money on stated terms, and a state chooses whether to accept. If it accepts, it can be held to those terms and can lose funding if it does not comply.
The majority opinion, by Justice Gorsuch, takes that analogy one step further. A state that takes federal money can be bound by the conditions it agreed to. But if Congress wants to go beyond the risk of lost funds and expose a particular person to private lawsuits for damages, the majority says that person must also have voluntarily and knowingly agreed to that liability. It is not enough that a state agency accepted the funds; the individual whose own assets are at stake must have clearly consented to be personally sued under the statute.
Who Actually Consented?
In this case, the majority reasoned, LDOC, by accepting federal corrections funding, agreed to comply with RLUIPA’s conditions–including the possibility of suits for “appropriate relief.” However, the individual officers did not. They never themselves made any agreement with the federal government or otherwise clearly accepted personal RLUIPA liability as the price of federal money flowing to the prison system.
Because RLUIPA’s prison provisions in this case rest on the spending power, and because the officers had not individually consented to personal liability, the Court held that RLUIPA cannot be used to recover damages from them in their personal capacities.
The Court emphasized that it was not deciding every question about RLUIPA. It did not resolve whether “appropriate relief” includes money damages against funding recipients like the state itself, nor did it address how RLUIPA works when it relies on other constitutional powers. It answered only the question presented by this record: when RLUIPA is operating as a spending‑condition statute, a prisoner may not obtain money damages under it from individual state prison officials who have not themselves agreed to that liability.
Hollow Promises?
Three justices disagreed. In dissent, Justice Jackson, joined by Justices Sotomayor and Kagan, argued that RLUIPA’s text closely tracks a related statute where the Court has already allowed damages suits against individual officials, and that Spending Clause laws are still laws, not private contracts. On that view, Congress could both require prisons that take federal funds to respect prisoners’ religious exercise and allow prisoners to seek money from officers who violate those protections, without needing each officer to separately “sign on” to personal liability.
In practical terms, the ruling leaves RLUIPA’s basic promise in place at the system level: state prison departments that take certain federal funds must still avoid unjustified burdens on prisoners’ religious exercise. But it draws a clear line at personal liability, and it signals judicial skepticism about using spending‑based statutes to reach individual actors who never expressly agreed to be personally on the hook.
