Sossamon v. Texas

Background

Harvey Leroy Sossamon III, an inmate in a Texas prison, sued the State and prison officials under RLUIPA, saying two policies — restricting attendance during cell restriction and barring chapel worship — substantially burdened his religious exercise and seeking money and injunctions. The District Court granted summary judgment for respondents, holding sovereign immunity barred money damages, and the Fifth Circuit affirmed. After the suit was filed the prison later changed some policies, making parts of the injunctive claims moot.

Reasoning

The Court examined whether RLUIPA’s phrase “appropriate relief against a government” clearly and unambiguously lets private plaintiffs recover money from States that accept federal funds. Applying longstanding rules that a waiver of state immunity must be explicit and strictly construed, the majority concluded the phrase is ambiguous and does not plainly include money damages. The Court stressed that ambiguity must be resolved in favor of the State, rejected the Spending Clause contract analogy, and held a separate Rehabilitation Act waiver did not clearly cover RLUIPA’s subsection addressing substantial burdens.

Real world impact

The decision means people suing States under RLUIPA cannot obtain money damages; sovereign immunity bars those claims. Plaintiffs may still seek non‑monetary relief like injunctions or declarations, but such remedies can be mooted by transfers or policy changes, limiting practical redress. That practical limit worries some judges because many prisoner claims end when inmates move or policies change. The Court affirmed the Fifth Circuit’s judgment against Sossamon on damages and left open the possibility that Congress could amend RLUIPA to authorize money relief.

Dissents or concurrances

Justice Sotomayor, joined by Justice Breyer, dissented. She argued that under general remedies principles monetary relief is the ordinary remedy for statutory violations, that “appropriate relief” therefore includes damages, and that the majority’s reading undermines Congress’ purpose to provide broad protection for institutionalized persons and makes enforcement harder.