Landor v. Louisiana Department of Corrections

In Landor v. Louisiana, the Supreme Court ruled that the Religious Land Use and Institutionalized Persons Act (RLUIPA) does not permit inmates to sue prison officials for money damages in their individual capacities. The majority opinion, authored by Justice Gorsuch, grounded this decision in the Spending Clause, explaining that federal statutes tied to funding are akin to contracts. Since the individual officers were not parties to the funding agreement between the federal government and the state, they never voluntarily consented to personal liability. The Court rejected arguments that the Necessary and Proper Clause allowed for such lawsuits, maintaining that Congress cannot bypass the requirement of consent to regulate private conduct directly. In a sharp dissent, Justice Jackson argued that the ruling turns federal law into a mere invitation and leaves victims of religious freedom violations without a meaningful remedy. Overall, the case reinforces a contract-based framework for spending legislation that shields non-contracting state employees from personal financial consequences.