Landor v. Louisiana Dept. of Corrections (23-1197)
- Term
- OT 2025
- Argued
- 2025-11-10
- Decided
- 2026-06-23
- Vote
- 6-3 for Louisiana Dept. of Corrections
- Opinion
- Justice Gorsuch
- Majority
- Gorsuch, Roberts, Thomas, Alito, Kavanaugh, Barrett
- Dissent
- Jackson, Sotomayor, Kagan
Holding
Affirmed the Fifth Circuit 6-3 for the Louisiana DOC. GORSUCH delivered the opinion of the Court, joined by Roberts, Thomas, Alito, Kavanaugh, and Barrett. JACKSON dissented, joined by Sotomayor and Kagan. Held: individuals may NOT be held liable in their personal capacities under a Spending Clause statute (RLUIPA) unless they voluntarily and knowingly consented to answer such suits; the individual LDOC officers never entered any agreement with the federal government and so did not consent, and Landor's case cannot proceed against them. The Court grounded the decision on the SPENDING CLAUSE consent requirement (Pennhurst clear-statement / contract analogy, Medina v. Planned Parenthood), NOT on the RFRA-parity question. It systematically rejected each of Landor's theories: agency law (a principal's agents do not become liable for the principal's nonperformance), South Dakota v. Dole (Dole's requirements are additive to, not a substitute for, the knowing-and-voluntary-consent rule), money fungibility / indirect-recipient (a penny of federal spending reaching an individual cannot manufacture consent), and Sabri / Necessary and Proper (suits against nonconsenting parties do not safeguard funds from being 'frittered away in graft'). Tanzin was distinguished, not extended: RFRA is not a Spending Clause statute, so its individual-capacity holding does not control the RLUIPA Spending-Clause consent question.
Pre-decision prediction
Landor 6-3 (72% confidence).
Opinion of the Court
Authored by Justice Gorsuch (15,791 words total).
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 authority 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 answer federal suits by private plaintiffs alleging certain substantial burdens 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 officers 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 appeal, 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 under a Spending Clause statute unless those individuals have voluntarily and knowingly consented to answer lawsuits under the statute; because the individual defendants in this case did not voluntarily 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 “terminate” its agreement to provide funds. Id., at 365–366 (internal quotation 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 employed a “contract analogy” that helps to ensure conditions attached to federal funds—including those prescribing exposure to potential sanctions—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 federal government, let alone that any of them has voluntarily and knowingly 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 precedents, 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,
Syllabus arguing that his proposed cause of action satisfies Dole’s four requirements and therefore satisfies the Spending Clause too. But Dole’s requirements apply in addition to—not instead of—the rule that Congress 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 defendants 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 Congress’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 answering the wrong question. The correct question is instead whether such a cause of action is a necessary and proper incident to Congress’s enumerated power to spend money. Suits against nonconsenting parties like the individual officers here might advance RLUIPA’s policy but do not safeguard federal funds from being “frittered away in graft.” Id., at 605. Adopting Mr. Landor’s proposed cause of action would allow Congress to evade the consent requirement inherent in its Spending Clause authority and regulate directly the conduct of countless nonconsenting individuals in spheres traditionally reserved to the States. Such a result would be inconsistent with principles of state sovereignty and a federal government of limited and enumerated regulatory powers. Pp. 15–18. 82 F. 4th 337, affirmed. GORSUCH, J., delivered the opinion of the Court, in which ROBERTS, C. J., and THOMAS, ALITO, KAVANAUGH, and BARRETT, JJ., joined.
PUBLIC SAFETY Syllabus
JACKSON, J., filed a dissenting opinion, in which SOTOMAYOR and KAGAN, JJ., joined.
Opinion of the Court NOTICE: This opinion is subject to formal revision before publication in the United States Reports. Readers are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, pio@supremecourt.gov, of any typographical or other formal errors.
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