Landor v. Louisiana Dept of Corrections (RLUIPA Individual Capacity Liability)

Current understanding

The Supreme Court held that individual state prison officers cannot be sued for money damages in their personal capacity under the Religious Land Use and Institutionalized Persons Act (RLUIPA). Because RLUIPA was enacted under the Spending Clause, only entities that voluntarily and knowingly accept federal funds — the state institutions themselves — can be treated as consenting to suit; individual officers never gave such consent under Pennhurst. Practical effect: incarcerated people whose religious exercise is substantially burdened by prison staff can still seek injunctive relief and can sue the institution, but cannot recover personal damages from the officer responsible.

Evidence log

• 2026-06-23 — Landor v. Louisiana Dept of Corrections and Public Safety: cross-connection with federal-prison-medical-care: Both concern the practical enforceability of rights held by incarcerated persons against prison officials; Landor limits monetary remedies against individual staff for religious-exercise violations. (novelty: 3)

Open questions

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