Landorv.Louisiana Department of Corrections and Public Safety
A Louisiana prisoner alleged that correctional officers forcibly shaved his religiously significant dreadlocks despite his invocation of the Religious Land Use and Institutionalized Persons Act. He sought damages from the officers in their individual capacities. The Supreme Court held that RLUIPA does not authorize such personal-capacity damages. Because RLUIPA’s institutionalized-person provisions rest on Congress’s Spending Clause authority, liability depends on the recipient’s knowing and voluntary acceptance of federal funding conditions. Individual employees do not themselves accept the federal funds or receive clear notice that doing so would expose them to personal damages. The judgment rejecting the individual-capacity claim was affirmed.
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