SCOTUS Delivers Victory for Limited Govt, Religious Liberty Protections

Landor sued the Louisiana Department of Corrections and Public Safety, Secretary James LeBlanc, the correctional center, and Warden Marcus Myers under RLUIPA and other claims, seeking money damages from the officials in their personal capacities.

Lower courts dismissed those individual claims, citing precedent that RLUIPA – enacted as a condition on federal prison funding – does not expose state employees to personal financial liability absent their knowing consent.

Writing for the majority, Justice Gorsuch emphasized a bedrock principle of constitutional law: When Congress acts under the Spending Clause, it may attach conditions to federal funds, but it cannot unilaterally create personal liability for state actors without clear, voluntary acceptance of those terms.

“Spending Clause legislation is in the nature of a contract,” Gorsuch explained.