Landor v. Louisiana Dept of Corrections and Public Safety
609 U. S. ___ (2026) · 6/23/26
State employees may not be held liable in their personal capacities under a Spending Clause statute such as the Religious Land Use and Institutionalized Persons Act of 2000 unless those individuals have voluntarily and knowingly consented to answer private suits under the statute; the individual defendants in this case did not do so here, so Landor’s case cannot proceed against them.
Edition: slip opinion, revised 6/28/26
Voices: Syllabus — prepared by the Reporter of Decisions · Justice Gorsuch delivered the opinion of the Court. · Justice Jackson, with whom Justice Sotomayor and Justice Kagan join, dissenting.
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. See 42 U. S. C. §§2000cc–1(a), (b)(1). Relying on that provision, inmate Damon Landor brought this RLUIPA lawsuit against LDOC as well as some of the prison…
Held: Individuals may not be held liable in their personal capacities under a Spending Clause statute unless those individuals have voluntarily and knowingly consented to answer lawsuits under the statute; because the individual defendants in this case did not voluntarily and knowingly consent to face RLUIPA liability in an agreement with the federal government, Mr. Landor’s case cannot proceed against them. Pp. 3–18. (a) While the Constitution’s “Spending Clause,” Art. I, §8, cl. 1, may confer on Congress the power to spend money for the general welfare, it does not “endow Congress with…Read it in the reading room ›