Sossamon v. Texas

Background

Harvey Leroy Sossamon III, a prisoner in a Texas prison, sued the State of Texas and prison officials under RLUIPA. He challenged policies that restricted inmates on cell restriction from attending religious services and that limited chapel worship. He sought both court orders to change policies and money to compensate for injuries. Lower courts held that sovereign immunity barred his claims for money damages, and the Fifth Circuit affirmed.

Reasoning

The Court asked whether a State waives its immunity to private money-damages suits under RLUIPA simply by accepting federal funds. The majority said no. It explained that a waiver of sovereign immunity must be 'unequivocal' in the statute's text. The phrase 'appropriate relief' is ambiguous and does not clearly and unambiguously include money damages. The Court rejected arguments that the Spending Clause contract analogy or a residual waiver in another statute forced a different result. Because the statute does not unambiguously authorize damages against States, sovereign immunity bars damages claims.

Real world impact

The ruling prevents private money-damages claims against States under the part of RLUIPA at issue. Injunctive or declaratory relief may still be available, but monetary compensation from state treasuries is not. The decision may leave some prisoners without compensation and can make suits harder if officials change policies or transfers occur. Congress could amend the law if it wants to allow damages.

Dissents or concurrances

Justice Sotomayor (joined by Justice Breyer) dissented, arguing that 'appropriate relief' plainly includes monetary damages under ordinary remedies principles and that the majority undermines RLUIPA's goal of broad protection for religious exercise.