Supreme Court rules prisoners may not seek monetary damages for violation of rights

[JURIST] The US Supreme Court [official website; JURIST news archive] on Wednesday ruled [opinion, PDF] 6-2 in Sossamon v. Texas [Cornell LII Backgrounder] that states do not consent to waive their sovereign immunity to private suits for money damages under the Religious Land Use and Institutionalized Persons Act (RLUIPA) [42 USC § 2000cc, text]. Petitioner Harvey Sossamon sought injunctive and monetary relief from the state of Texas under RLUIPA for prison policies that prohibited him from using the prison chapel for worship. Justice Clarence Thomas, writing for the majority, rejected Sossamon's argument that the words "appropriate relief" in RLUIPA unambiguously waives the state's immunity from damages. Thomas stated that because "appropriate" is context dependent, "appropriate relief" is open-ended and ambiguous about the relief it includes. The court declined to consider a state to have waived its sovereign immunity where a statute can be inferred to have several plausible interpretations. Thomas also rejected Sossamon's contention that because RLUIPA § 3 was enacted pursuant to the Spending Clause [text] of the US Constitution, the states were on notice that they would be liable for damages because Spending Clause legislation operates as a contract, and damages are always available for breach of contract:

Applying ordinary contract principles here would also make little sense because contracts with a sovereign are unique: They do not traditionally confer a right of action for damages to enforce compliance. More fundamentally, Sossamon's implied-contract remedy cannot be squared with the rule that a sovereign immunity waiver must be expressly and unequivocally stated in the relevant statute's text.
The court also rejected Sossamon's attempt to apply § 1003 of the Rehabilitation Act Amendments of 1986's express waiver of state sovereign immunity for violations of any federal statute prohibiting discrimination by recipients of federal financial assistance. Thomas argued that RLUIPA § 3, which prohibits substantial burden on religious exercise, is not unequivocally a statute explicitly prohibiting discrimination within § 1003's meaning. Justice Sonia Sotomayor wrote for the dissent, and maintained that monetary damages are the usual remedy for violation of a legal right under the general remedies principles and included in the phrase "appropriate relief." Justice Elena Kagan took no part in the decision.

The court's ruling affirms the decision [opinion, PDF] by the US Court of Appeals for the Fifth Circuit [official website] that Sossamon was barred from suing for monetary damages because the language in RLUIPA did not provide clear notice to Texas that it was waiving its rights to sovereign immunity from monetary damages. The court heard oral arguments [oral argument transcript, PDF; JURIST report] in the case last year. At oral arguments counsel for Sossamon argued that damages were an appropriate remedy. Counsel for the US government argued as amicus curiae on behalf of the petitioner. Counsel for Texas argued that the ambiguous phrase "appropriate relief" does not permit damages.

 

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