Landor v. Louisiana Dept of Corrections and Public Safety
Key claim: The Supreme Court held that individual state prison officers cannot be held personally liable under RLUIPA because they never voluntarily and knowingly consented to answer suits under the Spending Clause statute.
Abstract
U.S. Supreme Court opinion decided 2026-06-23, by Neil Gorsuch. (Slip Opinion) OCTOBER TERM, 2025 1
Syllabus
NOTE: Where it is feasible, a syllabus (headnote) will be released, as is
being done in connection with this case, at the time the opinion is issued.
The syllabus constitutes no part of the opinion of the Court but has been
prepared by the Reporter of Decisions for the convenience of the reader.
See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.
SUPREME COURT OF THE UNITED STATES
Syllabus
LANDOR v. LOUISIANA DEPARTMENT OF
CORRECTIONS AND PUBLIC SAFETY ET AL.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT
No. 23–1197. Argued November 10, 2025—Decided June 23, 2026 The Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA) was enacted pursuant to Congress’s Spending Clause au- thority and imposes various conditions on federal funds distributed to state prison systems like the Louisiana Department of Corrections (LDOC). One condition requires state prison systems to agree to an- swer federal suits by private plaintiffs alleging certain substantial bur- dens on their religious exercises. See 42 U. S. C. §§2000cc–1(a), (b)(1). Relying on that provision, inmate Damon Landor brought this RLUIPA lawsuit against LDOC as well as some of the prison system’s individual officers in their personal capacities, seeking damages from them. Mr. Landor is a Rastafarian whose religious convictions require him to leave his hair uncut. He claims that LDOC officers—despite being aware of his religious beliefs—forcibly shaved his head. The of- ficers moved to dismiss, arguing that while their employer LDOC may have agreed to answer certain private suits under RLUIPA, they were not parties to any such agreement, and therefore Mr. Landor had no federal cause of action against them. The district court dismissed Mr. Landor’s RLUIPA claims against both the officers and LDOC. On ap- peal, Mr. Landor challenged only the dismissal of his claim against the individual officers. The Fifth Circuit declined to revive that portion of his suit, holding that RLUIPA does not permit suits against officers in their individual capacities. Held: Individuals may not be held liable in their personal capacities un- der a Spending Clause statute unless those individuals have voluntar- ily and knowingly consented to answer lawsuits under the statute; be- cause the individual defendants in this case did not voluntarily and 2 LANDOR v. LOUISIANA DEPT. OF CORRECTIONS AND PUBLIC SAFETY Syllabus
knowingly consent to face RLUIPA liability in an agreement with the
federal government, Mr. Landor’s case cannot proceed against them.
Pp. 3–18.
(a) While the Constitution’s “Spending Clause,” Art. I, §8, cl. 1, may
confer on Congress the power to spend money for the general welfare,
it does not “endow Congress with [any] power to regulate conduct.”
Medina v. Planned Parenthood South Atlantic, 606 U. S. 357, 370.
Congress may attach conditions to the funds it distributes, and if a
recipient “violates those conditions,” Congress typically may “termi-
nate” its agreement to provide funds. Id., at 365–366 (internal quota-
tion marks omitted). But Congress cannot dictate whatever other
sanctions it might wish for violating conditions found in its Spending
Clause legislation. Additional sanctions are permissible only with the
“voluntar[y] and knowin[g]” consent of those who must bear them.
Pennhurst State School and Hospital v. Halderman, 451 U. S. 1, 17.
To sort out whether consent exists, the Court has traditionally em-
ployed a “contract analogy” that helps to ensure conditions attached to
federal funds—including those prescribing exposure to potential sanc-
tions—apply only to those who have knowingly and voluntarily agreed
to them. Pp. 3–8.
(b) These settled principles resolve this case. Before this Court,
LDOC does not dispute that it is a recipient of federal funds and has
agreed to answer certain RLUIPA suits as a condition of accepting
those funds. But this case involves only claims against individual state
employees in their personal capacities, and Mr. Landor does not allege
that any of those individuals has entered any agreement with the fed-
eral government, let alone that any of them has voluntarily and know-
ingly consented to answer private suits under RLUIPA. 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 action might
proceed against a defendant who never formed a contract. P. 8.
(c) Mr. Landor’s arguments are all variations on the theme that the
lack of voluntary and knowing consent does not matter. And they all
fail for that reason. Under the Spending Clause and the Court’s prec-
edents, the consent requirement is key. Pp. 9–18.
(1) Mr. Landor invokes agency law, arguing that LDOC employees
may be held liable because they are LDOC’s agents. But as a matter
of blackletter law, when a principal enters a contract with a third
party, the principal’s agents do not become liable to the third party for
their principal’s nonperformance. LDOC might be subject to certain
private suits under RLUIPA if it breaches its promises to the federal
government, but it does not follow that LDOC’s employees are as well.
Pp. 9–10.
(2) Mr. Landor next turns to South Dakota v. Dole, 483 U. S. 203,
Cite as: 609 U. S. ___ (2026) 3
Syllabus
arguing that his proposed cause of action satisfies Dole’s four require- ments and therefore satisfies the Spending Clause too. But Dole’s re- quirements apply in addition to—not instead of—the rule that Con- gress may not use the Spending Clause to bind entities and individuals without their knowing and voluntary consent. Dole itself added a fifth rule barring compulsion and reaffirmed the clear-statement rule, both of which serve to ensure real consent exists. Mr. Landor also argues that RLUIPA’s mere existence sufficed to alert the individual defend- ants that they could be held personally liable. This argument fares no better. A Spending Clause statute assumes binding effect only through “voluntar[y] and knowin[g]” agreement, which is lacking here. Pennhurst, 451 U. S., at 17. Pp. 10–12. (3) Mr. Landor next turns to the fungibility of money, contending that the individual defendants are indirect recipients of federal funds because they receive paychecks from LDOC. But this argument would mean that so long as a penny of federal spending makes its way to an individual, Congress could directly regulate his conduct based on the fiction that he has consented to regulation. This is inconsistent with the requirement of knowing and voluntary consent, and it would give Congress an effectively unbridled police power impossible to square with the Spending Clause’s terms or our precedents. Pp. 12–15. (4) Mr. Landor’s reliance on the Necessary and Proper Clause and Sabri v. United States, 541 U. S. 600, is misplaced. In Sabri, the Court held that Congress’s criminal ban on theft, fraud, or bribery against a federal funding recipient is a necessary and proper incident to Con- gress’s authority to spend money. 541 U. S., at 605–606. Mr. Landor contends that his proposed cause of action is likewise incidental to RLUIPA’s policy protecting religious exercises. But Mr. Landor is an- swering the wrong question. The correct question is instead whether such a cau
[This finding represents 2 closely related documents issued 2026-06-23 (same source, same action). Related: scotus:10878535]
Why this matters
Landor materially reduces the deterrent and remedial toolkit available to incarcerated people whose religious exercise is burdened by individual prison staff: injunctive relief and institutional liability remain, but personal damages against the officer who imposed the burden are off the table. The ruling reinforces a broader Spending Clause consent doctrine that will likely constrain individual-capacity suits under other conditional-funding civil rights statutes, shaping how prisoners, disability claimants, and Title IX plaintiffs can enforce their rights going forward.