On June 23, 2026, the Supreme Court decided Landor v. Louisiana Department of Corrections and Public Safety, No. 23-1197, holding that a former Louisiana inmate could not sue state prison officials in their personal capacities for violating his religious beliefs because the officials did not voluntarily and knowingly consent to face lawsuits in their personal capacities when Congress used its spending powers to pass the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA).
RLUIPA was enacted pursuant to Congress's authority under the Spending Clause of the US Constitution. RLUIPA imposes conditions on federal funds distributed to state prison systems, including a requirement that those systems refrain from imposing substantial burdens on prisoners' religious exercise, absent exceptional circumstances.
Damon Landor is a Rastafarian who follows the religion's Nazarite vow against cutting one's hair. In 2020, while in custody in a Louisiana prison, Mr. Landor was transferred to a new facility, where prison guards handcuffed him to a chair and shaved his head, despite him showing the guards a copy of a Fifth Circuit decision holding that it was unlawful under RLUIPA for the Louisiana Department of Corrections to shave dreadlocks of a fellow Rastafarian.
After his release from custody, Mr. Landor sued the prison guards and the facility's then-warden, seeking monetary damages from each of them in their individual capacities for violating his rights under RLUIPA when they shaved him. The district court dismissed his claims and the Fifth Circuit affirmed, ruling that RLUIPA does not permit lawsuits against individuals in their personal capacity for monetary damages.
The US Supreme Court affirmed. Writing for the Court, Justice Gorsuch explained that the Spending Clause allows Congress to attach conditions to federal funds, but it does not give Congress general power to regulate conduct. Under Spending Clause precedents, additional sanctions beyond termination of funds require the voluntary and knowing consent of those who must bear them. Justice Gorsuch used a contract-law analogy: the federal government offers funds, a recipient agrees to certain conditions, and the resulting obligations flow from that agreement. "Under the Spending Clause, Congress lacks regulatory authority to impose liability on [government officials] directly and must depend instead on consent," he said. "And because they never agreed to answer suits like this one, Mr. Landor's case cannot proceed against them any more than a breach of contract might proceed against a defendant who never formed a contract."
The Court distinguished this case from a prior decision in Tanzin v. Tanvir, which determined that identical language in the Religious Freedom Restoration Act (RFRA)—RLUIPA's federal sister statute — allows plaintiffs to pursue claims against federal officials in their individual capacities. The Court distinguished Landor from Tanzin by focusing on the source of Congress's authority to enact the statute at issue. Although both RFRA and RLUIPA authorize "appropriate relief against a government," RLUIPA's institutionalized-persons provisions were enacted pursuant to Congress's Spending Clause authority, under which federal funding statutes operate like contracts between the federal government and the funding recipient. By contrast, RFRA is not a Spending Clause statute, and therefore does not implicate the clear-notice and consent principles that govern federal funding legislation.
Justice Gorsuch delivered the opinion of the Court, in which Chief Justice Roberts and Justices Thomas, Alito, Kavanaugh, and Barrett joined. Justice Jackson authored a dissenting opinion, which was joined by Justices Sotomayor and Kagan.
