Landor v. Louisiana Dept of Corrections and Public Safety · ¶44
Nothing similar can be said for the cause of action Mr. Landor and the dissent propose. Suits against nonconsenting parties, like the individual officers here, might advance RLUIPA’s laudable policy of protecting religious exercises. But they do not safeguard from graft the federal funds Congress distributes pursuant to its spending power. Recognizing as much, seemingly every Court of Appeals to address the question has concluded that Sabri does not begin to command the result Mr. Landor and the dissent seek. See Tripathy v. McKoy, 103 F. 4th 106, 115 (CA2 2024) (“Sabri is easily distinguishable”); Sharp v. Johnson, 669 F. 3d 144, 155, n. 15 (CA3 2012) (“Sabri is inapposite”); Haight v. Thompson, 763 F. 3d 554, 570 (CA6 2014) (“RLUIPA is nothing like the Sabri statute”); Barnett v. Short, 129 F. 4th 534, 543 (CA8 2025) (Sabri “is too dissimilar”); Wood v. Yordy, 753 F. 3d 899, 903 (CA9…Read in context ›
slip opinion, revised 6/28/26
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