Landor v. Louisiana Dept of Corrections and Public Safety · ¶76

So too here. Indeed, Tanzin’s reasoning applies with even more force to RLUIPA. RLUIPA’s prison context redoubles Tanzin’s observation that damages will often be not only an appropriate form of relief but “the only form of relief ” available. Id., at 51. The Prison Litigation Reform Act’s exhaustion requirement and strict limitations on injunctive relief in prisons, coupled with States’ ability to transfer prisoners and thereby moot claims for injunctive relief, mean that withholding a damages remedy will often leave prisoners with no remedy at all.

slip opinion, revised 6/28/26
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