Staff Reports
The Supreme Court this week handed down a ruling that will make civil suits against prison guards harder to win — even when the guards did something everyone agrees was wrong. In a 6–3 decision, the Court said a Rastafari inmate who was forcibly shaved cannot collect money damages from the individual guards under the Religious Land Use and Institutionalized Persons Act (RLUIPA). The justices agreed the guards violated religious liberty, but they still closed off this path for money damages.
What the Court actually decided
Justice Neil Gorsuch wrote the majority opinion and explained the case as a Spending-Clause question. The Court said RLUIPA is a law tied to federal funds, and those rules bind the funding recipient (the State), not individual employees who never agreed to be personally bound. In the Court’s words, “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.” Chief Justice Roberts joined the majority along with Justices Thomas, Alito, Kavanaugh, and Barrett.
Why this matters for remedies and deterrence
Put plainly: if an inmate is moved or released before a judge can issue an injunction, damages against individual guards were often the only realistic way to get relief. The ruling narrows that option. The dissent, led by Justice Ketanji Brown Jackson and joined by Justices Sotomayor and Kagan, warned that this decision undercuts RLUIPA’s purpose and leaves little incentive for officials to follow the law. As Jackson put it, “It is not often that a real-life incident so clearly illustrates Congress’s reasons for adopting legislation.” That’s a sharp rebuke — and it highlights the human cost of legal formalism.
A conservative take: rule of law, but demand accountability
As a conservative, I’m glad the Court applied a clear rule on Spending-Clause statutes. You can’t quietly saddle state workers with personal liability they never agreed to. That protects employees from surprise lawsuits and preserves predictable constitutional rules. But let’s not pretend this is an excuse to shrug at misconduct. The guards’ conduct was shameful. States and attorneys general should act: adopt clearer policies, discipline or prosecute bad actors, and defend religious liberty in their prisons. Louisiana’s attorney general said the state condemned the incident and changed policy — that’s the right starting point.
The Court narrowed one legal path, but it didn’t remove all avenues for justice. Plaintiffs can still sue state entities in their official capacity where allowed, bring municipal claims, or press other federal or state causes of action. If Congress wants individual damages restored under RLUIPA, it can legislate a remedy that makes the spending bargain explicit. Until then, conservatives should support the rule-of-law principle shown by the majority — and also insist that government institutions police their own agents so that obvious wrongs like this don’t keep happening.
