Inmate Can't Sue Texas Over Religious Hurdles
(CN) - Texas should not face a damages trial for allegedly depriving a prisoner of religious exercise, the Supreme Court ruled, 6-2, Wednesday, finding that states have immunity from such claims.
A Texas prisoner, Harvey Leroy Sossamon III, sued the state and several corrections officers in 2006 for injunctive and monetary relief under the Religious Land Use and Institutionalized Persons Act.
He claimed that one prison policy prevented inmates from attending religious services if they were on cell restriction for disciplinary infractions, and he said there was a general policy that barred him from using the prison chapel.
A federal judge dismissed the suit on the basis of immunity, and the 5th Circuit affirmed in 2009. Sossamon had claimed that Texas waived its sovereign immunity by accepting federal funds, but the majority affirmed that this was not the case.
While the trial court denied both the claims for monetary and injunctive relief, the monetary claim is the only one at issue in this case because the circuit concluded that the policy changes at Sossamon's prison mooted the need for an injunction.
Sossamon claimed on appeal that states necessarily waive their immunity since Congress passed the Religious Land Use and Institutionalized Persons Act pursuant to its Spending Clause and Commerce Clause authority. Invoking spending powers put the states on notice that they may be liable for damages, he claimed.
"He argues that Spending Clause legislation operates as a contract and damages are always available relief for a breach of contract, whether the contract explicitly includes a damages remedy or not," Justice Clarence Thomas wrote for the majority.
But the argument ultimately fails, the justices found. "In any event, applying ordinary contract principles here would make little sense because contracts with a sovereign are unique," Thomas wrote. "They do not traditionally confer a right of action for damages to enforce compliance. ...
"More fundamentally, Sossamon's implied-contract remedies proposal cannot be squared with our longstanding rule that a waiver of sovereign immunity must be expressly and unequivocally stated in the text of the relevant statute. It would be bizarre to create an 'unequivocal statement' rule and then find that every Spending Clause enactment, no matter what its text, satisfies that rule because it includes unexpressed, implied remedies against the States."
In a dissenting opinion, Justices Sonia Sotomayor and Stephen Breyer said that the text of the Religious Land Use and Institutionalized Persons Act is more explicit that the majority found.
"No one disputes that, in accepting federal funds, the States consent to suit for violations of RLUIPA's substantive provisions; the only question is what relief isavailable to plaintiffs asserting injury from such violations," Sotomayor wrote. "That monetary damages are 'appropriate relief' is, in my view, self-evident. Under general remedies principles, the usual remedy for a violation of a legal right is damages."
Justice Elena Kagan did not participate in the consideration or decision of this case. Oral arguments occurred in November.