Landor v. Louisiana Dept of Corrections and Public Safety · ¶79

It is true, though, that while the relevant statutory text is the same, the two statutes’ fonts of power are not. It is on this observation that respondents rest their statutory argument. Unlike RFRA, RLUIPA relies on (as relevant here) the Spending Clause. Any divergence between the statutes’ meanings, then, would have to come not from text but from constitutional inference—something particular to the Spending Clause compelling us not to adopt the same reading of that same statutory language. When interpreting Spending Clause legislation, we have used a contract analogy to require that Congress express its intent to impose conditions on the receipt of federal funds “unambiguously.” Barnes v. Gorman, 536 U. S. 181, 186 (2002) (internal quotation marks omitted). Under our precedent, this is where contract-law principles should come into play—not as a substantive limitation on Congress’s…

slip opinion, revised 6/28/26
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