SPEAKER_00 0:01

Hello, this is RJ Deakin, reading the Supreme Court of United States opinion syllabus in Lander versus Louisiana Department of Corrections and Public Safety, Sertiari to the United States Court of Appeals for the Fifth Circuit, argued November 10, 2025, and decided June 23rd, 2026. The Religious Land Use and Institutionalized Persons Act of 2000, R-L-U-I-P-A, 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, L D O C One condition requires state prison systems to agree to an to answer federal suits by private plaintiffs alleging certain substantial burdens on their religious exercises. C forty eight USC sections two thousand C C one B one. Relying on that provision, inmate Damon Landor brought this R L U I P A 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. Lander's RLUIPA claims against both the officers and LDC. On appeal, Mr. Lander 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. The Supreme Court held a decision below is affirmed, and Justice Gorsuch delivered the opinion. 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 knowingly consent to face R L U IPA liability in an agreement with the federal government, Mr. Lander's case cannot proceed against them. While the Constitution's spending clause, Article 1, Section 8, Clause 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. That's uh Medina versus Planned Parenthood, South Atlantic. That's 606 US 357 at 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. But Congress cannot dictate whether other sanctions whatever, 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 voluntary and knowing consent of those who must bear them. That's Penhurst State School and Hospital versus Hallerman. 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. 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 R L U IPA 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 R L U I P A, 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.

unknown 5:07

Mr.

SPEAKER_00 5:07

Lander's arguments are all variations on the theme that the lack of voluntary and knowing consent does not matter, and that they all fail for that reason. Under the spending clause and the court's precedence, the consent requirement is key. Mr. Lander invokes agency law, arguing that LDOC employees may be held liable because they are LDOC's agents, but as a matter of black letter 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 non-performance. LDOC might be subject to certain private suits under L R L U I P A if it breaches its promises to the federal government, but it does not follow that LDOC's employees are as well.

unknown 6:01

Mr.

SPEAKER_00 6:02

Lander next turns to South Dakota versus Dole, 483 US 203, 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. Lander also argues that R L U IPA's mere existence sufficed to alert the individual defendants that they could be held personally liable. This argument fares no better. The spending clause statute assumes binding effect only through voluntary and knowing agreement, which is lacking here. Mr. Lander next turns to the fungibility of money, contending that the individual defendants are indirect recipients of federal funds because they receive paychecks from LDLC. 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 precedence.

unknown 7:50

Mr.

SPEAKER_00 7:50

Lander'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. Mr. Lander contends that his proposed cause of action is likewise incidental to R L U IPA's policy protecting religious exercises. But Mr. Lander 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 non-consenting parties like the individual officers here might advance RLUIPA's policy, but do not safeguard federal funds from being frittered away in graft. Adopting Mr. Lander'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 the principles of state sovereignty and a federal government of limited and enumerated regulatory powers. The decision below is affirmed. Justice Gorsuch delivered the opinion of the court in which Chief Justice Roberts and Justices Thomas Alito, Kavanaugh, and Barrett joined. Justice Jackson filed a dissenting opinion in which Justices Sotomayor and Kegan joined. Thanks for listening.