Summary
The Fifth Circuit held that the Religious Land Use and Institutionalized Persons Act (RLUIPA) does not authorize money damages against state officials in their individual capacities, reaffirming its prior decision in *Sossamon v. Lone Star State of Texas*. The court distinguished the Supreme Court's holding in *Tanzin v. Tanvir*, which allowed individual-capacity damages under the Religious Freedom Restoration Act (RFRA), because RLUIPA was enacted under Congress's Spending Clause power, not Section 5 of the Fourteenth Amendment. Consequently, a Rastafarian inmate's RLUIPA claim for monetary relief after prison officials forcibly shaved his head was dismissed. The case also rejected arguments that *Sabri v. United States* extended Spending Clause liability to non-recipient individuals in civil RLUIPA suits.
Topics
Practice areas
Questions Presented
- Whether the Religious Land Use and Institutionalized Persons Act (RLUIPA) provides for money damages against officials sued in their individual capacities.
Holdings
- RLUIPA does not permit suits for money damages against officials in their individual capacities.
Key quotations
“The question presented is whether the Religious Land Use and Institutionalized Persons Act ('RLUIPA') provides for money damages against officials sued in their individual capacities.” (at 1)
“In Sossamon I, we plainly held that RLUIPA does not permit suits against officers in their individual capacities, which, in turn, means claimants cannot recover monetary damages.” (at 4)
“Because the district court correctly held so, we AFFIRM.” (at 12)
Factual background
Damon Landor, a Rastafarian, was incarcerated in 2020. He had taken a Nazarite vow not to cut his hair. At two previous facilities, his religious accommodation was respected. When transferred to Raymond Laborde Correctional Center with three weeks left in his sentence, an intake guard and warden Marcus Myers refused to acknowledge his religious accommodation and forced him to have his head shaved against his will. Landor sued under RLUIPA and other laws.
Procedural history
The district court dismissed Landor's RLUIPA claims against defendants in their individual capacities for money damages, holding that such claims are not allowed under RLUIPA. Landor appealed.