131 S. Ct. 1651 (2011)
In 2006, Harvey Leroy Sossamon III, an inmate in the Robertson Unit of the Texas Department of Criminal Justice, Correctional Institutions Division, sued the State of Texas and various prison officials in their official capacities under RLUIPA’s private cause of action, seeking injunctive and monetary relief for alleged violations of his religious exercise rights.1
Sossamon challenged two prison policies that he claimed substantially burdened his religious exercise: a policy that prevented inmates on cell restriction for disciplinary infractions from attending religious services, and a policy that barred use of the prison chapel for religious worship.2
The District Court granted summary judgment to the respondents, holding that sovereign immunity barred Sossamon’s claims for monetary relief.3
On appeal, the Fifth Circuit affirmed the dismissal of the monetary claims, concluding that Texas had not waived its sovereign immunity by accepting federal funds because the phrase “appropriate relief against a government” did not unambiguously notify the State of a damages waiver.4 The court also held that Sossamon’s claim for injunctive relief regarding the cell-restriction policy was moot because the State had abandoned that policy after he filed a prison grievance, but it reversed the District Court on the chapel-use policy claim.5
Subsequently, the Robertson Unit amended its chapel policy to permit inmates to attend scheduled worship services subject to safety precautions.6 The Supreme Court granted certiorari to resolve a division of authority among the Courts of Appeals on whether acceptance of federal funds under RLUIPA waives sovereign immunity to suits for money damages.7
Whether the States, by accepting federal funds, consent to waive their sovereign immunity to suits for money damages under the Religious Land Use and Institutionalized Persons Act of 2000?8
A State's consent to suit must be unequivocally expressed in the text of RLUIPA.9
No. The established facts show that Harvey Leroy Sossamon III filed suit in 2006 against the State of Texas and prison officials seeking monetary relief under RLUIPA for two prison policies.10 The District Court granted summary judgment barring the monetary claims on sovereign immunity grounds.11 The Fifth Circuit affirmed that Texas had not waived immunity by accepting federal funds because the phrase appropriate relief against a government did not unambiguously notify the State of a damages waiver.12 The Supreme Court granted certiorari to resolve the split among circuits on this exact question.13
The rule requires an unequivocal textual statement before a State can be held to have waived immunity through Spending Clause legislation.14 RLUIPA's private cause of action provision supplies only the open-ended term appropriate relief.15 That term does not clearly and unambiguously extend to monetary claims against a sovereign.16 The facts confirm that Sossamon sought damages for the cell-restriction and chapel-use policies, yet no statutory language expressly notified Texas that acceptance of funds would expose it to such liability.17 Strict construction therefore preserves immunity.18
States do not consent to waive their sovereign immunity to suits for money damages under RLUIPA by accepting federal funds.19
Related opinions on this issue
Joined by Justice Breyer
Justice Sotomayor dissented on the ground that the phrase appropriate relief supplies clear notice under general remedies principles that monetary damages are available.20 She reasoned that damages are the default remedy for violation of a federal right and that precedents such as Franklin confirm the term encompasses monetary relief.21 In her view the majority's contrary reading undermines the broad protection of religious exercise that Congress expressly intended RLUIPA to provide.22
Justice Sotomayor further explained that RLUIPA straightforwardly provides a private right of action to obtain appropriate relief against a government.23 Under traditional remedies principles, damages are the default and equitable relief the exception.24 She noted that precedents like Franklin and Barnes make clear that the phrase appropriate relief includes monetary relief against violators of substantive terms.25 By adopting a contrary reading, the majority severely undermines the broad protection of religious exercise Congress intended the statute to provide.26
Whether the phrase 'appropriate relief against a government' in 42 U.S.C. § 2000cc-2(a) provides the unequivocal textual waiver of state sovereign immunity required for monetary damages claims?27
Because a waiver of sovereign immunity must be unequivocally expressed and is strictly construed in favor of the sovereign, the open-ended phrase appropriate relief does not unambiguously include money damages against a State.28
No. The established facts establish that Sossamon's 2006 complaint expressly sought monetary relief against Texas for the cell-restriction and chapel policies.29 The District Court and Fifth Circuit both held that the statutory language failed to provide the required clear statement.30 The Supreme Court agreed that appropriate relief is inherently context-dependent and does not clearly identify damages when the defendant is a sovereign whose treasury would be exposed.31
Application of the rule to these facts shows that multiple plausible readings exist, one of which preserves immunity.32 The Court therefore could not conclude that Texas unequivocally consented to damages suits merely by accepting federal funds.33 The subsequent amendment of the chapel policy and mootness ruling on injunctive relief further illustrate that the litigation centered on whether damages remained available after equitable claims fell away.34
The phrase appropriate relief against a government in 42 U.S.C. § 2000cc-2(a) does not provide the unequivocal textual waiver of state sovereign immunity required for monetary damages claims.35
Related opinions on this issue
Joined by Justice Breyer
Justice Sotomayor maintained that the term appropriate relief is not ambiguous because background remedies principles treat damages as the ordinary remedy.36 She argued that state officials reading the statute would understand from Franklin and Barnes that the phrase includes monetary relief.37 She criticized the majority for discovering ambiguity where none exists in light of the statute's plain terms.38
Justice Sotomayor added that if state officials reading RLUIPA were uncertain whether appropriate relief encompasses monetary damages, precedents would relieve any doubt.39 In Franklin the Court made clear that absent clear direction to the contrary, federal statutes providing a private right of action authorize all appropriate relief including damages.40 She concluded that the majority's position cannot be reconciled with RLUIPA's plain terms and the principles animating prior precedents.41
Whether Section 1003 of the Rehabilitation Act Amendments of 1986, 42 U.S.C. § 2000d-7, independently waives state sovereign immunity to damages suits under RLUIPA § 3?42
Section 1003's residual clause waives immunity only for federal statutes that prohibit discrimination; RLUIPA § 3 prohibits substantial burdens on religious exercise and therefore falls outside the clause.43
No. The established facts show that Sossamon relied on RLUIPA § 3, which bars substantial burdens rather than discrimination, to seek damages.44 The Fifth Circuit and Supreme Court both rejected the argument that § 1003 independently waived immunity.45 The text of § 3 does not use the term discrimination, in contrast to RLUIPA § 2, and the specific statutes listed in § 1003 all explicitly prohibit discrimination.46
Strict construction of the residual clause in favor of the sovereign confirms that a State could reasonably conclude it covers only provisions employing the term discrimination.47 The facts of this litigation, which involved only § 3 claims arising from prison policies, therefore do not trigger the § 1003 waiver.48
Section 1003 of the Rehabilitation Act Amendments of 1986 does not independently waive state sovereign immunity to damages suits under RLUIPA § 3.49