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U.S. Supreme Court: No Monetary Damages Against States Under RLUIPA
On April 20, 2011, the U.S. Supreme Court ruled that state sovereign immunity bars recovery of monetary damages under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. § 2000cc, et seq.
Harvey Leroy Sossamon III, a Texas state prisoner incarcerated at the Robertson Unit, filed a RLUIPA action against the Texas Dept. of Criminal Justice (TDCJ), prison officials and the State of Texas. RLUIPA, in pertinent part, creates a cause of action against government agencies or officials who impose a substantial burden on the religious rights of prisoners or detainees that does not further a compelling governmental interest.
The law allows an aggrieved prisoner to obtain “appropriate relief.”
Congress enacted RLUIPA under its Spending Clause and Commerce Clause authority in response to the U.S. Supreme Court finding the Religious Freedom Restoration Act, 42 U.S.C. § 2000bb, et seq., was unconstitutional as applied to state and local governments. See: City of Boerne v. Flores, 52 U.S. 507 (1997) [PLN, Sept. 1997, p.15]. The Spending Clause authority simply means that the statute applies to any state or local government agency that accepts federal funding.
Sossamon alleged that two TDCJ policies violated RLUIPA: 1) a policy that prevented prisoners from attending religious services while on cell restriction for disciplinary infractions, and 2) a policy barring use of the prison chapel for religious worship. The district court granted summary judgment in favor of the defendants, holding that “sovereign immunity barred Sossamon’s claims for monetary relief.” He then appealed.
The Fifth Circuit Court of Appeals affirmed the district court’s judgment, strictly construing the text of RLUIPA’s cause of action section in favor of the defendants and concluding that “the statutory phrase ‘appropriate relief against a government’ did not ‘unambiguously notify’ Texas that the acceptance of federal funds was conditioned on the waiver of immunity from claims for money damages.” [See: PLN, June 2010, p.30]. Separately, the Sixth Circuit also held that RLUIPA does not allow monetary damages. [See: PLN, June 2010, p.47].
Upon review of the appellate decision in Sossamon’s case, the Supreme Court noted that “dual sovereignty” is a fundamental feature in the Constitution. This essentially means that states entered into the union “with their sovereignty intact.”
“Immunity from private suits has long been considered ‘central to sovereign dignity.’” Therefore, a state is immune from private lawsuits brought in federal court unless it “unequivocally expressed” its desire to waive sovereign immunity. For such an unequivocal expression to occur in the context of a federal statute, the text of the relevant statute must contain a “clear declaration” that sovereign immunity is being waived.
RLUIPA’s authorization of “appropriate relief” is not an unequivocal expression of waiver. Therefore, the Supreme Court found that it cannot “be certain that the State in fact consents” to be sued. “‘Appropriate relief’ is open-ended and ambiguous about what types of relief it includes, as many lower courts have recognized,” the Court wrote. The wording is context-dependent and therefore open to multiple plausible interpretations, some of which do not include monetary damages. Therefore, strictly construing that statutory phrase in favor of the state, the Supreme Court concluded that RLUIPA does not authorize lawsuits for money damages.
Neither construing RLUIPA as a contract nor considering the residual clause in § 1003 of the Rehabilitation Act, 42 U.S.C. § 2000d-7, altered this assessment. The judgment of the Fifth Circuit was accordingly affirmed. Prisoners who sue state agencies or officials under RLUIPA can obtain injunctive relief, but not monetary damages. Prisoner plaintiffs desiring money damages must sue under the First Amendment. See: Sossamon v. Texas, 131 S.Ct. 1651 (2011).
Harvey Leroy Sossamon III, a Texas state prisoner incarcerated at the Robertson Unit, filed a RLUIPA action against the Texas Dept. of Criminal Justice (TDCJ), prison officials and the State of Texas. RLUIPA, in pertinent part, creates a cause of action against government agencies or officials who impose a substantial burden on the religious rights of prisoners or detainees that does not further a compelling governmental interest.
The law allows an aggrieved prisoner to obtain “appropriate relief.”
Congress enacted RLUIPA under its Spending Clause and Commerce Clause authority in response to the U.S. Supreme Court finding the Religious Freedom Restoration Act, 42 U.S.C. § 2000bb, et seq., was unconstitutional as applied to state and local governments. See: City of Boerne v. Flores, 52 U.S. 507 (1997) [PLN, Sept. 1997, p.15]. The Spending Clause authority simply means that the statute applies to any state or local government agency that accepts federal funding.
Sossamon alleged that two TDCJ policies violated RLUIPA: 1) a policy that prevented prisoners from attending religious services while on cell restriction for disciplinary infractions, and 2) a policy barring use of the prison chapel for religious worship. The district court granted summary judgment in favor of the defendants, holding that “sovereign immunity barred Sossamon’s claims for monetary relief.” He then appealed.
The Fifth Circuit Court of Appeals affirmed the district court’s judgment, strictly construing the text of RLUIPA’s cause of action section in favor of the defendants and concluding that “the statutory phrase ‘appropriate relief against a government’ did not ‘unambiguously notify’ Texas that the acceptance of federal funds was conditioned on the waiver of immunity from claims for money damages.” [See: PLN, June 2010, p.30]. Separately, the Sixth Circuit also held that RLUIPA does not allow monetary damages. [See: PLN, June 2010, p.47].
Upon review of the appellate decision in Sossamon’s case, the Supreme Court noted that “dual sovereignty” is a fundamental feature in the Constitution. This essentially means that states entered into the union “with their sovereignty intact.”
“Immunity from private suits has long been considered ‘central to sovereign dignity.’” Therefore, a state is immune from private lawsuits brought in federal court unless it “unequivocally expressed” its desire to waive sovereign immunity. For such an unequivocal expression to occur in the context of a federal statute, the text of the relevant statute must contain a “clear declaration” that sovereign immunity is being waived.
RLUIPA’s authorization of “appropriate relief” is not an unequivocal expression of waiver. Therefore, the Supreme Court found that it cannot “be certain that the State in fact consents” to be sued. “‘Appropriate relief’ is open-ended and ambiguous about what types of relief it includes, as many lower courts have recognized,” the Court wrote. The wording is context-dependent and therefore open to multiple plausible interpretations, some of which do not include monetary damages. Therefore, strictly construing that statutory phrase in favor of the state, the Supreme Court concluded that RLUIPA does not authorize lawsuits for money damages.
Neither construing RLUIPA as a contract nor considering the residual clause in § 1003 of the Rehabilitation Act, 42 U.S.C. § 2000d-7, altered this assessment. The judgment of the Fifth Circuit was accordingly affirmed. Prisoners who sue state agencies or officials under RLUIPA can obtain injunctive relief, but not monetary damages. Prisoner plaintiffs desiring money damages must sue under the First Amendment. See: Sossamon v. Texas, 131 S.Ct. 1651 (2011).
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Related legal case
Sossamon v. Texas
| Year | 2011 |
|---|---|
| Cite | 131 S.Ct. 1651 (2011) |
| Level | Supreme Court |
| Injunction Status | N/A |