A Texas inmate filed suit against the state of Texas and its prison officials, claiming that he was denied a fair opportunity to engage in Christian worship services in violation of the Religious Land Use and Institutionalized Persons Act (RLUIPA) and other federal and state law. He and other inmates in disciplinary confinement were barred from leaving their cells to attend religious services, even though other inmates were permitted to leave their cells for secular activities. Similarly, he and other inmates were prohibited from using the prison chapel for religious services, while other inmates were allowed to use the chapel for non-religious purposes. The plaintiff sought declaratory, injunctive, and monetary relief.
The federal district court granted summary judgment to the defendants based on sovereign immunity with respect to the claims for monetary damages. (Sovereign immunity is a legal doctrine that prevents people from suing a state without that state’s consent.) The U.S. Court of Appeals for the Fifth Circuit affirmed. It found that Texas did not lose its sovereign immunity because RLUIPA’s authorization of claims for “appropriate relief” was “not clear enough” to cut off such immunity, even though the RLUIPA unambiguously created a right of action for damages.
The plaintiff petitioned the U.S. Supreme Court for a writ of certiorari, which the Court granted to answer the limited question “[w]hether an individual may sue a State or a state official in his official capacity for damages for violations of [RLUIPA].”
In August 2010, Americans United and several other religious and civil-liberties organizations filed an amicus brief. The brief argued that damages are often the only effective means of deterring prison officials from imposing unjustified burdens on religious exercise in prisons, since prisons can easily “moot” claims for injunctive relief by transferring the prisoner to another location, only burdening the specific prisoner’s religious exercise once, or granting the prisoner an accommodation. It further argued that the Fifth Circuit erred in deeming the term “appropriate relief” in RLUIPA to be ambiguous. That term, when used in other federal statutes, has long been interpreted by the Court to include monetary damages. Under the Court’s longstanding rule of statutory interpretation, we argued, the term should retain its meaning across statutes.
In a 6–2 decision issued on April 20, 2011, the Court affirmed the Fifth Circuit’s ruling, holding that Congress had not eliminated states’ immunity from suit for damages under RLUIPA. The Court explained that a waiver of sovereign immunity must be unequivocally expressed in the text of a statute, and the Act’s authorization of “appropriate relief” was ambiguous.
