Landor v. Louisiana Dept of Corrections and Public Safety · ¶106

Notably, the majority does not contest the premise that Louisiana’s prison officials must abide by RLUIPA. And it admits, as it must, that a court may order prison officials in their official capacities to comply with RLUIPA. See ante, at 15, n. 6. But this leaves the majority in an odd spot. In the majority’s view, the prison official’s relationship to the State is close enough that “the actions of ” the official are “the actions of the [State] itself ” such that the official may stand in for the State in litigation, Brandon v. Holt, 469 U. S. 464, 472 (1985), but distant enough that the State’s consent to damages liability on the official’s behalf means nothing at all. There is no rational basis for that distinction.

slip opinion, revised 6/28/26
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