Supreme Court Rules Prison Officials Can’t Face RLUIPA Suit

In Landor v. Louisiana Department of Corrections and Public Safety, 609 U.S. ___ (2026), the U.S. Supreme Court held that prisoners can’t sue individual officers for monetary damages under the Religious Land Use and Institutionalized Persons Act (RLUIPA), unless those individuals have voluntarily and knowingly consented to answer private suits under the statute. Applying this rule, the justices further found that Damon Landor’s case could not proceed.

Facts of the Case

The Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA) was enacted pursuant to 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.

Relying on that provision, inmate Damon Landor brought this RLUIPA lawsuit against LDOC as well as some of the prison system’s individual officers in their personal capacities, seeking damages from them. Landor is a Rastafarian whose religious convictions require him to leave his hair uncut. He claims that LDOC officers—despite being aware of his religious beliefs—forcibly shaved his head.

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 therefore Landor had no federal cause of action against them. The district court dismissed Landor’s RLUIPA claims against both the officers and LDOC. On appeal, Landor challenged only the dismissal of his claim against the individual officers. The Fifth Circuit Court of Appeals declined to revive that portion of his suit, holding that RLUIPA does not permit suits against officers in their individual capacities.

Supreme Court’s Decision

The U.S. Supreme Court affirmed by a vote of 6-3. “Mr. Landor does not have a federal RLUIPA cause of action against the officers. Under the Spending Clause, Congress lacks regulatory authority to impose liability on them directly and must depend instead on consent,” Justice Neil Gorsuch wrote on behalf of the majority. “And because they never agreed to answer suits like this one, Mr. Landor’s case cannot proceed against them any more than a breach of contract action might proceed against a defendant who never formed a contract.”

In reaching its decision, the majority relied heavily on the Spending Clause and the Court’s precedents interpreting it. As Justice Gorsuch explained, the Constitution’s Spending Clause authorizes Congress to spend money for the general welfare, but it does not “endow Congress with [any] power to regulate conduct.” Congress may only attach conditions to the funds it distributes, and if a recipient violates those conditions, Congress typically may end its agreement to provide funds.

Citing Pennhurst State School and Hospital v. Halderman, 451 U.S. 1 (1981), Justice Gorsuch went on to explain that the Court has consistently held that additional sanctions are permissible only with the “voluntar[y] and knowin[g]” consent of those who must bear them.

“Put simply, without independent regulatory authority, Congress must rely on consent. It must ask and others must agree to face liability should they violate a funding condition,” Justice Gorsuch wrote. “Time and time again, from at least 1845 to the present, our precedents have stressed the centrality of consent in this field.”

According to the Court, these “settled principles” resolve the case. Under the majority’s reasoning, because the prison officials never agreed to answer suits like this one, Landor’s case can’t proceed against them any more than a breach of contract action might proceed against a defendant who never formed a contract. Justice Gorsuch wrote:

Before us, LDOC does not dispute that it is a recipient of federal funds. It does not question that it has agreed to answer certain RLUIPA suits as a condition of accepting those funds. But as it comes to us, this case does not involve claims against LDOC. It involves only claims against individuals in their personal capacities. And Mr. Landor does not allege that any of those individuals has entered any agreement with the federal government, let alone that any of them has voluntarily and knowingly consented to answer private suits under RLUIPA.

The majority rejected all of Landor’s counterarguments suggesting that consent is not required. With regard to Landor’s argument that LDOC employees may be held liable because they are LDOC’s agents, Justice Gorsuch noted that as a matter of blackletter law, when a principal enters a contract with a third party, the principal’s agents do not become liable to the third party for their principal’s nonperformance.

Dissent

Justice Ketanji Brown Jackson wrote a dissenting opinion, joined by Justices Sonia Sotomayor and Elena Kagan. The dissenting justices argued that the majority erred in imposing an additional requirement on top of the Court’s settled Spending Clause framework. According to Justice Jackson, because of the majority’s flawed decision, “[p]risoners like Landor who suffer violations of their religious freedom in state prisons—no matter how blatant—will often be left remediless. And encroachments on prisoners’ statutory rights are likely to happen with fair frequency, as state-empowered prison officials will have little incentive to abide by federal law, even if it is handed to them on a piece of paper.”