Landor v. Louisiana Dept of Corrections and Public Safety · ¶98

The majority maintains that this is not Dole. RLUIPA is different, the majority says, because Congress has bound individual prison officials directly whereas the federal law in Dole did not act directly upon nonrecipients. Instead, that law “influence[d] a State’s legislative choices,” causing the State to regulate young drinkers. New York v. United States, 505 U. S. 144, 167 (1992) (discussing Dole); ante, at 12, n. 5. But that distinction makes no relevant difference. Either way, Congress has used its spending power to regulate individuals without their express consent. In Dole, the State exposed the individual to liability in exchange for federal funds. So too here.

slip opinion, revised 6/28/26
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