Inmates Can’t Get Monetary Damages In Religion Cases, Says Supreme Court

The U.S. Supreme Court has ruled that prison inmates cannot seek monetary damages from the state when their rights under a federal religious liberty law are violated.

The Religious Land Use and Institutionalized Persons Act (RLUIPA) was passed in part to protect prisoners’ rights to practice their religion.

The case before the high court considered a situation at a Texas penitentiary, in which Harvey Sossamon III and other inmates on disciplinary restrictions were not allowed to attend Christian services in the prison chapel. However, inmates were allowed to use the chapel for non-religious purposes and could leave their cells for non-religious reasons, such as educational classes and using the library.

Sossamon, arguing that the policy violated his religious freedom, filed a lawsuit against Texas. He claimed that since the state receives some federal funds to run the prison, he should be entitled to “appropriate relief” under RLUIPA.

Both the federal district court and the 5th U.S. Circuit Court of Appeals dismissed Sossamon’s claim, citing state sovereign immunity, a legal doctrine that protects states from lawsuits seeking monetary damages.

In a 6-2 ruling April 20, the Supreme Court agreed with the lower courts.

Writing for the majority in Sossamon v. Texas, Justice Clarence Thomas said that states do not waive sovereign immunity merely because they receive money from the federal government.

The ruling still allows prisoners to receive other types of relief under the statute. This means a court could still order a state to change prison policies that burden inmates’ religious freedom and violate RLUIPA.

Justice Sonia Sotomayor, joined by Justice Stephen Breyer, dissented, asserting that denying money damages “severely undermines” the intent of Congress in passing RLUIPA in 2000. (Justice Elena Kagan recused herself due to prior involvement in the case as solicitor general.)

“By depriving prisoners of a damages remedy for violations of their statutory rights,” observed Sotomayor, “the majority ensures that plaintiffs suing state defendants under RLUIPA will be forced to seek enforcement of those rights with one hand tied behind their backs.”

Americans United joined with seven organizations on a friend-of-the-court brief, urging the court to rule in favor of monetary relief. The organizations asserted that denying such damages gives states little incentive to protect inmates’ religious liberty.

Groups signing the brief include the Baptist Joint Committee for Religious Liberty, the American Jewish Committee, the American Civil Liberties Union and the Interfaith Alliance Foundation.

The brief asserted that the purpose of RLUIPA is to deter “pervasive and unjustified burdens on religious exercise.” It asserts that in order to achieve this, prisoners need to be able to seek both injunctive and monetary remedies.