Landor v. Louisiana Dept of Corrections and Public Safety Revisions: 6/24/26 (2026)

(Slip Opinion) OCTOBER TERM, 2025 1 Syllabus NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337. SUPREME COURT OF THE UNITED STATES Syllabus LANDOR v. LOUISIANA DEPARTMENT OF CORRECTIONS AND PUBLIC SAFETY ET AL. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT No. 23–1197. Argued November 10, 2025—Decided June 23, 2026 The Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA) was enacted pursuant to Congress’s Spending Clause au- thority and imposes various conditions on federal funds distributed to state prison systems like the Louisiana Department of Corrections (LDOC). One condition requires state prison systems to agree to an- swer federal suits by private plaintiffs alleging certain substantial bur- dens on their religious exercises. See 42 U. S. C. §§2000cc–1(a), (b)(1). Relying on that provision, inmate Damon Landor brought this RLUIPA lawsuit against LDOC as well as some of the prison system’s individual officers in their personal capacities, seeking damages from them. Mr. Landor is a Rastafarian whose religious convictions require him to leave his hair uncut. He claims that LDOC officers—despite being aware of his religious beliefs—forcibly shaved his head. The of- ficers moved to dismiss, arguing that while their employer LDOC may have agreed to answer certain private suits under RLUIPA, they were not parties to any such agreement, and therefore Mr. Landor had no federal cause of action against them. The district court dismissed Mr. Landor’s RLUIPA claims against both the officers and LDOC. On ap- peal, Mr. Landor challenged only the dismissal of his claim against the individual officers. The Fifth Circuit declined to revive that portion of his suit, holding that RLUIPA does not permit suits against officers in their individual capacities. Held: Individuals may not be held liable in their personal capacities un- der a Spending Clause statute unless those individuals have voluntar- ily and knowingly consented to answer lawsuits under the statute; be- cause the individual defendants in this case did not voluntarily and 2 LANDOR v. LOUISIANA DEPT. OF CORRECTIONS AND PUBLIC SAFETY Syllabus knowingly consent to face RLUIPA liability in an agreement with the federal government, Mr. Landor’s case cannot proceed against them. Pp. 3–18. (a) While the Constitution’s “Spending Clause,” Art. I, §8, cl. 1, may confer on Congress the power to spend money for the general welfare, it does not “endow Congress with [any] power to regulate conduct.” Medina v. Planned Parenthood South Atlantic, 606 U. S. 357, 370. Congress may attach conditions to the funds it distributes, and if a recipient “violates those conditions,” Congress typically may “termi- nate” its agreement to provide funds. Id., at 365–366 (internal quota- tion marks omitted). But Congress cannot dictate whatever other sanctions it might wish for violating conditions found in its Spending Clause legislation. Additional sanctions are permissible only with the “voluntar[y] and knowin[g]” consent of those who must bear them. Pennhurst State School and Hospital v. Halderman, 451 U. S. 1, 17. To sort out whether consent exists, the Court has traditionally em- ployed a “contract analogy” that helps to ensure conditions attached to federal funds—including those prescribing exposure to potential sanc- tions—apply only to those who have knowingly and voluntarily agreed to them. Pp. 3–8. (b) These settled principles resolve this case. Before this Court, LDOC does not dispute that it is a recipient of federal funds and has agreed to answer certain RLUIPA suits as a condition of accepting those funds. But this case involves only claims against individual state employees in their personal capacities, and Mr. Landor does not allege that any of those individuals has entered any agreement with the fed- eral government, let alone that any of them has voluntarily and know- ingly consented to answer private suits under RLUIPA. Because they never agreed to answer suits like this one, Mr. Landor’s case cannot proceed against them any more than a breach of contract action might proceed against a defendant who never formed a contract. P. 8. (c) Mr. Landor’s arguments are all variations on the theme that the lack of voluntary and knowing consent does not matter. And they all fail for that reason. Under the Spending Clause and the Court’s prec- edents, the consent requirement is key. Pp. 9–18. (1) Mr. Landor invokes agency law, arguing that LDOC employees may be held liable because they are LDOC’s agents. But as a matter of blackletter law, when a principal enters a contract with a third party, the principal’s agents do not become liable to the third party for their principal’s nonperformance. LDOC might be subject to certain private suits under RLUIPA if it breaches its promises to the federal government, but it does not follow that LDOC’s employees are as well. Pp. 9–10. (2) Mr. Landor next turns to South Dakota v. Dole, 483 U. S. 203, Cite as: 609 U. S. ___ (2026) 3 Syllabus arguing that his proposed cause of action satisfies Dole’s four require- ments and therefore satisfies the Spending Clause too. But Dole’s re- quirements apply in addition to—not instead of—the rule that Con- gress may not use the Spending Clause to bind entities and individuals without their knowing and voluntary consent. Dole itself added a fifth rule barring compulsion and reaffirmed the clear-statement rule, both of which serve to ensure real consent exists. Mr. Landor also argues that RLUIPA’s mere existence sufficed to alert the individual defend- ants that they could be held personally liable. This argument fares no better. A Spending Clause statute assumes binding effect only through “voluntar[y] and knowin[g]” agreement, which is lacking here. Pennhurst, 451 U. S., at 17. Pp. 10–12. (3) Mr. Landor next turns to the fungibility of money, contending that the individual defendants are indirect recipients of federal funds because they receive paychecks from LDOC. But this argument would mean that so long as a penny of federal spending makes its way to an individual, Congress could directly regulate his conduct based on the fiction that he has consented to regulation. This is inconsistent with the requirement of knowing and voluntary consent, and it would give Congress an effectively unbridled police power impossible to square with the Spending Clause’s terms or our precedents. Pp. 12–15. (4) Mr. Landor’s reliance on the Necessary and Proper Clause and Sabri v. United States, 541 U. S. 600, is misplaced. In Sabri, the Court held that Congress’s criminal ban on theft, fraud, or bribery against a federal funding recipient is a necessary and proper incident to Con- gress’s authority to spend money. 541 U. S., at 605–606. Mr. Landor contends that his proposed cause of action is likewise incidental to RLUIPA’s policy protecting religious exercises. But Mr. Landor is an- swering the wrong question. The correct question is instead whether such a cause of action is a necessary and proper incident to Congress’s enumerated power to spend money. Suits against nonconsenting par- ties like the individual officers here might advance RLUIPA’s policy but do not safeguard federal funds from being “frittered away in graft.” Id., at 605. Adopting Mr. Landor’s proposed cause of action would al- low Congress to evade the consent requirement inherent in its Spend- ing Clause authority and regulate directly the conduct of countless nonconsenting individuals in spheres traditionally reserved to the States. Such a result would be inconsistent with principles of state sovereignty and a federal government of limited and enumerated reg- ulatory powers. Pp. 15–18. 82 F. 4th 337, affirmed. GORSUCH, J., delivered the opinion of the Court, in which ROBERTS, C. J., and THOMAS, ALITO, KAVANAUGH, and BARRETT, JJ., joined. 4 LANDOR v. LOUISIANA DEPT. OF CORRECTIONS AND PUBLIC SAFETY Syllabus JACKSON, J., filed a dissenting opinion, in which SOTOMAYOR and KAGAN, JJ., joined. Cite as: 609 U. S. ____ (2026) 1 Opinion of the Court NOTICE: This opinion is subject to formal revision before publication in the United States Reports. Readers are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, pio@supremecourt.gov, of any typographical or other formal errors. SUPREME COURT OF THE UNITED STATES _________________ No. 23–1197 _________________ DAMON LANDOR, PETITIONER v. LOUISIANA DEPARTMENT OF CORRECTIONS AND PUBLIC SAFETY, ET AL. ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT [June 23, 2026] JUSTICE GORSUCH delivered the opinion of the Court. This case concerns whether the Religious Land Use and Institutionalized Persons Act of 2000 permits plaintiffs to sue nonconsenting state employees in their private capaci- ties for damages. I Today, Congress offers financial support to all 50 States and many other entities. Much of that support comes with strings attached. So, for example, Congress has conditioned receipt of federal highway funds on a State’s agreement to maintain laws setting a minimum drinking age of 21. See South Dakota v. Dole, 483 U. S. 203 (1987). Likewise, Con- gress has conditioned federal Medicaid funds on a State’s willingness to administer its healthcare programs con- sistent with various rules. See Medina v. Planned Parenthood South Atlantic, 606 U. S. 357, 362–364 (2025). In each of these contexts and many others, the penalty for noncompliance is straightforward: Congress may “termi- nate funds” if a recipient fails to abide by the conditions 2 LANDOR v. LOUISIANA DEPT. OF CORRECTIONS AND PUBLIC SAFETY Opinion of the Court associated with its grants. Id., at 365–366 (internal quota- tion marks omitted). The statute at issue before us, the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), works similarly. As relevant here, RLUIPA imposes various con- ditions on federal funds distributed to state prison systems like the Louisiana Department of Corrections (LDOC). One condition requires prison systems to refrain from imposing “substantial burden[s] on the religious exercise[s]” of state prisoners outside exceptional circumstances. See 42 U. S. C. §§2000cc–1(a), (b)(1); see also Tr. of Oral Arg. 60. If a prison system fails to comply with that condition, Con- gress may cut off its funding. But when enacting RLUIPA, Congress did something more: It included another, distinct remedy as part of the bargain. As a condition of funding, Congress called on state prison systems to agree to answer suits by private plaintiffs alleging substantial burdens on their religious exercises. Specifically, the law asked those systems to consent to suit by any injured party “assert[ing] a violation of ” RLUIPA and seeking “appropriate relief.” §2000cc–2(a). This case concerns that provision. Damon Landor is a Rastafarian whose religious convictions require him to leave his hair uncut. In 2020, after a conviction in Louisi- ana state court, Mr. Landor spent a few months in custody. Near the end of his sentence, as officers transferred him from one facility to another, Mr. Landor grew concerned that the new facility’s intake officers might cut his hair pur- suant to standard LDOC grooming policies. To avoid that possibility, he provided the officers with a copy of Ware v. LDOC, 866 F. 3d 263 (CA5 2017), which held that RLUIPA generally bars prisons from cutting Rastafarians’ hair. See id., at 266, 274. But, Mr. Landor says, the LDOC officers in the new facility responded by throwing his copy of Ware in the trash and proceeding to shave his head, causing him to violate his religious beliefs. Cite as: 609 U. S. ____ (2026) 3 Opinion of the Court After that transpired, Mr. Landor brought this lawsuit under RLUIPA seeking money damages. He sued not only LDOC, but also some of the prison system’s individual of- ficers in their personal capacities. The officers responded by asking the district court to dismiss Mr. Landor’s com- plaint. As they saw it, their employer, LDOC, may have struck a bargain with the federal government to answer certain private suits by prisoners like Mr. Landor. But, they argued, they were not parties to that or any other agreement to answer private suits under RLUIPA. Accord- ingly, they continued, Mr. Landor had no federal cause of action against them. Ultimately, the court dismissed Mr. Landor’s RLUIPA claims against both LDOC and the offic- ers. On appeal to the Fifth Circuit, Mr. Landor did not chal- lenge the district court’s dismissal of his RLUIPA claim against LDOC. Instead, he focused on his claim against the individual officers, asking the Court of Appeals to revive only that portion of his suit. The Fifth Circuit declined to do so. It did not question that RLUIPA may permit certain claims against funding recipients like LDOC. But, the court held, RLUIPA “does not permit suits against officers in their individual capacities.” 82 F. 4th 337, 341 (2023). We granted Mr. Landor’s petition for a writ of certiorari. 606 U. S. 916 (2025). II Before us, the parties dispute two questions. One is whether, by authorizing private lawsuits seeking “appro- priate relief,” RLUIPA ever permits suits for money dam- ages—or whether the statute instead limits plaintiffs like Mr. Landor to other remedies, like injunctions or declara- tory judgments. Brief for Petitioner 2–3, 18–19; Brief for Respondents 4. The other question the parties spar over is whether, consistent with the Constitution, a plaintiff may bring an RLUIPA suit against individuals, like the officers 4 LANDOR v. LOUISIANA DEPT. OF CORRECTIONS AND PUBLIC SAFETY Opinion of the Court in this case, who have not formed any agreement with the federal government. Brief for Petitioner 38–46; Brief for Respondents 28–30, 45–46. To resolve this case, we need answer only the second question.1 Article I of the Constitution grants Congress certain lim- ited and enumerated powers. Congress, for example, may “regulate Commerce . . . among the several States.” Art. I, §8, cl. 3. It may “establish a uniform Rule of Naturaliza- tion, and uniform Laws on the subject of Bankruptcies.” Cl. 4. It may “coin Money” and “provide for the Punishment of counterfeiting.” Cls. 5–6. These provisions and others allow Congress to regulate the behavior of the American people in specific fields. And each allows Congress to back up its regulations “with a sanction” enforced either “by the COERTION of the magistracy, or by the COERTION of arms.” The Federalist No. 15, p. 95 (J. Cooke ed. 1961) (A. Hamil- ton). So, for example, federal statutes require airlines op- erating in interstate commerce to hold certificates and com- ply with federal requirements. See 49 U. S. C. §§41101, 41102, 41109. The Bankruptcy Code allows a court to alter a creditor’s rights and a debtor’s responsibilities. See Title 11. And Title 18, Chapter 25, criminalizes counterfeiting. See, e.g., 18 U. S. C. §473. Each of these regulations finds its footing in a provision of Article I that empowers Con- gress to do just that: regulate. The terms of RLUIPA before us rest on a different foun- dation. As the parties agree, Congress enacted them —————— 1 The dissent says we give “short shrift” to the principle that constitu- tional questions are to be avoided “ ‘if there is some other ground upon which to dispose of the case.’ ” Post, at 4 (opinion of JACKSON, J.) (quoting Bond v. United States, 572 U. S. 844, 855 (2014)). But this is a “pruden- tial rule,” Zobrest v. Catalina Foothills School Dist., 509 U. S. 1, 8 (1993), not a “mechanica[l ]” one, Almendarez-Torres v. United States, 523 U. S. 224, 239 (1998). And for reasons we outline, the constitutional question here is readily resolved by our precedents. It is also narrower than the statutory question in an important respect: It does not require us to ad- dress whether RLUIPA ever authorizes money damages. Cite as: 609 U. S. ____ (2026) 5 Opinion of the Court pursuant to what is sometimes called the Constitution’s Spending Clause. See Sossamon v. Texas, 563 U. S. 277, 290 (2011); Brief for Petitioner 3; Brief for Respondents 2. That provision of Article I gives Congress the “Power To lay and collect Taxes, Duties, Imposts and Excises, to pay the Debts and provide for the common Defence and general Welfare of the United States.” Art. I, §8, cl. 1. At the found- ing, some argued this language conferred on Congress the power to regulate on nearly any topic it wishes, backed by practically any sanction it chooses, so long as it does so in service of the “general Welfare.” See Medina, 606 U. S., at 370. It appears that Gouverneur Morris, a leading advocate of this reading and a member of the Committee on Style, even tried to replace one of the draft Clause’s commas with a semicolon with the hope of making his reading more plau- sible. See W. Treanor, The Case of the Dishonest Scrivener: Gouverneur Morris and the Creation of the Federalist Con- stitution, 120 Mich. L. Rev. 1, 20–24 (2021). But a careful proofreader—Roger Sherman—noticed the surreptitious edit, and the Convention rejected it. See ibid. In the end, the founding generation rejected Morris’s reading of the Clause just as it had his semicolon. See Me- dina, 606 U. S., at 370–371. While the Clause may allow Congress to raise and spend money in support of the “gen- eral Welfare,” early authorities concluded, it did not “endow Congress with [any] power to regulate conduct.” Ibid. (in- ternal quotation marks omitted). Were it otherwise, they recognized, “the ‘enumeration of specific powers’ elsewhere in Article I would be rendered largely pointless, and the Na- tion would trade a limited federal government for ‘an un- limited’ one.” Id., at 371 (quoting 2 J. Story, Commentaries on the Constitution of the United States §§904, 906, pp. 367, 369 (1833)). This Court’s precedents have long re- spected that founding-era consensus. See Medina, 606 U. S., at 371; accord, Cummings v. Premier Rehab Keller, 596 U. S. 212, 219 (2022). 6 LANDOR v. LOUISIANA DEPT. OF CORRECTIONS AND PUBLIC SAFETY Opinion of the Court It is an understanding that gives rise to important limi- tations on spending legislation. Often, Congress attaches conditions to the funds it distributes. And typically, if a re- cipient “violates those conditions,” Congress may “termi- nate” its agreement to provide funds. Medina, 606 U. S., at 365–366 (internal quotation marks omitted). But because the Spending Clause confers no authority to “regulate di- rectly,” Dole, 483 U. S., at 209, Congress cannot just dictate whatever other sanctions it might wish for violating condi- tions found in its Spending Clause legislation. Instead, additional sanctions are permissible only with the “voluntar[y] and knowin[g]” consent of those who must bear them. Pennhurst State School and Hospital v. Halder- man, 451 U. S. 1, 17 (1981). Put simply, without independ- ent regulatory authority, Congress must rely on consent. It must ask and others must agree to face liability should they violate a funding condition. Time and time again, from at least 1845 to the present, our precedents have stressed the centrality of consent in this field. Compare Searight v. Stokes, 3 How. 151, 169 (1845) (calling spending legislation a “compact . . . to which the state assented”), with Medina, 606 U. S., at 372 (describing spending statutes as “federal- state agreements”).2 —————— 2 See also, e.g., Neil, Moore & Co. v. Ohio, 3 How. 720, 742 (1845) (call- ing spending legislation “an agreement . . . between the United States and a state”); McGee v. Mathis, 4 Wall. 143, 155 (1866) (“It is not doubted that the grant by the United States to the State upon conditions, and the acceptance of the grant by the State, constituted a contract” founded on “consent of minds”); Steward Machine Co. v. Davis, 301 U. S. 548, 597– 598 (1937) (Spending legislation is an “agreemen[t] . . . with Congress”); Pennhurst, 451 U. S., at 17 (“[L]egislation enacted pursuant to the spend- ing power is much in the nature of a contract: in return for federal funds, the States agree to comply with federally imposed conditions”); Gebser v. Lago Vista Independent School Dist., 524 U. S. 274, 287 (1998) (discuss- ing the “contractual nature” of Title IX); Barnes v. Gorman, 536 U. S. 181, 186 (2002) (“We have repeatedly characterized . . . Spending Clause Cite as: 609 U. S. ____ (2026) 7 Opinion of the Court To sort out whether consent exists—and thus whether a condition associated with spending legislation is enforcea- ble—we have traditionally turned to contract principles for guidance. See Sossamon, 563 U. S., at 290 (The contract analogy represents “a . . . limitation on” the “liability” Spending Clause statutes may impose (emphasis deleted)). Consider some examples. At common law, coerced assent to a contract is invalid. See Restatement (Second) of Con- tracts §175(1) (1979). Likewise, we have held, coerced as- sent to a spending condition—by way of an economic “gun to the head”—is invalid. National Federation of Independ- ent Business v. Sebelius, 567 U. S. 519, 581–582 (2012) (opinion of ROBERTS, C. J.); see also id., at 676–677 (joint dissent of Scalia, Kennedy, THOMAS, and ALITO, JJ.); Dole, 483 U. S., at 211. At common law, ambiguous contractual language is construed against its drafter. See C & L Enter- prises, Inc. v. Citizen Band Potawatomi Tribe of Okla., 532 U. S. 411, 423 (2001). Similarly, we have concluded, Con- gress must clearly and unambiguously alert a grant recipi- ent to any condition on federal funds. Pennhurst, 451 U. S., at 17. In these ways and others, our “contract analogy” helps safeguard against conflating Congress’s spending power with a regulatory power. It does so by ensuring that conditions attached to federal funds—including those pre- scribing exposure to potential sanctions—apply only to those who have knowingly and voluntarily agreed to them. See Cummings, 596 U. S., at 220; cf. Medina, 606 U. S., at —————— legislation as much in the nature of a contract” (internal quotation marks omitted)); National Federation of Independent Business v. Sebelius, 567 U. S. 519, 577 (2012) (opinion of ROBERTS, C. J.) (“The legitimacy of Con- gress’s exercise of the spending power . . . rests on whether the State vol- untarily and knowingly accepts the terms of the contract” (internal quo- tation marks omitted)); Cummings v. Premier Rehab Keller, 596 U. S. 212, 219 (2022) (“Spending Clause legislation operates based on consent: in return for federal funds, the recipients agree to comply with federally imposed conditions” (internal quotation marks and alteration omitted)). 8 LANDOR v. LOUISIANA DEPT. OF CORRECTIONS AND PUBLIC SAFETY Opinion of the Court 371–372 (noting that an analogy to treaties, another con- sensual instrument, may also be appropriate).3 These settled principles resolve this case. Before us, LDOC does not dispute that it is a recipient of federal funds. It does not question that it has agreed to answer certain RLUIPA suits as a condition of accepting those funds. But as it comes to us, this case does not involve claims against LDOC. It involves only claims against individuals in their personal capacities. And Mr. Landor does not allege that any of those individuals has entered any agreement with the federal government, let alone that any of them has vol- untarily and knowingly consented to answer private suits under RLUIPA. To know that is enough to know the Court of Appeals was correct. Mr. Landor does not have a federal RLUIPA cause of action against the officers. Under the Spending Clause, Congress lacks regulatory authority to impose liability on them directly and must depend instead on consent. And because they never agreed to answer suits like this one, Mr. Landor’s case cannot proceed against them any more than a breach of contract action might proceed against a defend- ant who never formed a contract. —————— 3 The contract analogy operates “only as a potential limitation on lia- bility,” Cummings, 596 U. S., at 225 (internal quotation marks omitted), meaning that consent is a necessary but not sufficient condition for con- stitutionality. As we have explained, “the exercise of the spending power must [also] be in pursuit of the general welfare,” spending conditions must be “german[e] . . . to federal purposes,” and still “other constitu- tional provisions may provide an independent bar.” Dole, 483 U. S., at 207–208 (internal quotation marks omitted). A spending agreement that violates one of these requirements is invalid, just like “an illegal con- tract” at common law is invalid, even if freely assented to. Kaiser Steel Corp. v. Mullins, 455 U. S. 72, 77 (1982) (internal quotation marks omit- ted). Cite as: 609 U. S. ____ (2026) 9 Opinion of the Court III Seeking to avoid this conclusion, Mr. Landor and the dis- sent advance many arguments. But each is a variation on the same theme. In different ways, Mr. Landor and the dis- sent submit, the lack of voluntary and knowing consent does not matter. And each of their arguments fails for ex- actly that reason. Under the Spending Clause and our prec- edents, voluntary and knowing consent is key. A Mr. Landor begins by invoking agency and contract law. As LDOC’s agents, he contends, the individual defendants have a “duty to obey all reasonable directions” from their principal. Restatement (Second) of Agency §385(1) (1957). And, he adds, an agent’s actions can sometimes “bin[d] his principal” to a contract when he acts “within the scope of his authority.” United States v. Gooding, 12 Wheat. 460, 469 (1827); see also Restatement (Second) of Agency §140. From these common law principles, Mr. Landor reasons, it follows that the individual defendants in this case may be held personally liable under RLUIPA. Brief for Petitioner 31–33; see also post, at 13–14, 24, n. 10 (opinion of JACKSON, J.). That much does not follow even from the precepts Mr. Landor cites. Certainly, an agent usually must obey his principal’s directions and sometimes may bind his princi- pal. But when a principal (here, LDOC) enters a contract with a third party (here, the federal government), as a mat- ter of blackletter contract law the principal’s agents do not become “liable” to the third party for their principal’s “non- performance.” Restatement (Second) of Agency §328 (bold- face deleted); see also, e.g., 12 R. Lord, Williston on Con- tracts §35:34, p. 502 (4th ed. 2012) (“The agent cannot enforce the [principal’s] contract, nor is the agent bound by it” (footnote omitted)); Hodgson v. Dexter, 1 Cranch 345, 363 (1803) (Marshall, C. J., for the Court) (“It is too clear to be 10 LANDOR v. LOUISIANA DEPT. OF CORRECTIONS AND PUBLIC SAFETY Opinion of the Court controverted, that . . . contracts made on account of the gov- ernment . . . are obligatory on the government; not the [gov- ernment’s] officer”). So, yes, LDOC might be subject to cer- tain private suits under RLUIPA for breaching its promises to the federal government. But under normal principles of agency and contract law, that does not mean LDOC’s em- ployees are as well. To be sure, Mr. Landor and the dissent identify ways in which Congress could have lawfully imposed personal lia- bility on the individual defendants. For example, Congress could have said that, as a condition of federal funding to LDOC, its officers had to agree to enter separate contracts with the federal government consenting to answer suits un- der RLUIPA. Or Congress might have conditioned its funds on Louisiana’s agreement to exercise its own regulatory powers to adopt a state law cause of action enforceable against LDOC officers who violate RLUIPA. Brief for Peti- tioner 47; cf. post, at 23–24. But these untapped possibili- ties only underscore Mr. Landor’s bind. The first hypothet- ical has what this case does not, namely, an agreement between the federal government and the defendants. And in the second hypothetical, again unlike this case, the State would have exercised its own regulatory powers. See Ran- dolph v. Donaldson, 9 Cranch 76, 84–85 (1815) (Story, J., for the Court) (describing a Virginia statute that did essen- tially that in response to a federal request).4 B Next, Mr. Landor points to Dole. That case, he says, set out just four requirements for Spending Clause legisla- tion—and consent is not among them. As he reads Dole, a —————— 4 Nor, of course, does anything prevent Louisiana from acting on its own initiative to adopt a state law permitting damages in cases like this one. Indeed, counsel for the individual officers before us indicated that just such a claim may be available to Mr. Landor under state law in state court. Tr. of Oral Arg. 113–114. Cite as: 609 U. S. ____ (2026) 11 Opinion of the Court condition on the grant of federal funds need only be “(1) in pursuit of the general welfare; (2) unambiguously ex- pressed; (3) related to the federal interest in particular na- tional projects or programs; and (4) not in violation of other constitutional provisions.” Brief for Petitioner 33 (citing 483 U. S., at 207–208; internal quotation marks omitted). And because a condition requiring nonconsenting individu- als to answer RLUIPA suits satisfies all these require- ments, Mr. Landor concludes, his case may proceed. The dissent appears to agree, suggesting that the voluntary and knowing consent requirement finds no support in “any of Dole’s prongs.” Post, at 13. That is incorrect. The four rules Mr. Landor extracts from Dole apply in addition to—not instead of—the rule that Congress may not use the Spending Clause to bind en- tities and individuals without their knowing and voluntary consent. That much is evident from Dole itself. As the dis- sent admits, Dole proceeds to add a fifth rule for Spending Clause legislation shortly after the passage Mr. Landor cites: Funding conditions may not “pass the point at which pressure turns into compulsion.” 483 U. S., at 211 (internal quotation marks omitted); post, at 12–13. And that bar on compulsion, as we have seen, serves to help ensure real con- sent exists. See Part II, supra. The same holds true of the clear-statement rule that Dole reaffirmed. Congress must impose spending conditions “unambiguously,” not for no reason, but so that participants in federally funded pro- grams may “exercise their choice knowingly, cognizant of the consequences of their participation.” 483 U. S., at 207 (internal quotation marks omitted). Had Dole meant to bulldoze the consent requirement and condone consent-free regulation under the Spending Clause, post, at 14–15, it would have had no occasion to emphasize any of this. Nor does Mr. Landor’s and the dissent’s consent-free gloss on Dole merely overlook important qualifications in Dole itself. Worse still, their misreading would pit that decision 12 LANDOR v. LOUISIANA DEPT. OF CORRECTIONS AND PUBLIC SAFETY Opinion of the Court against nearly two centuries’ worth of cases recognizing the consent requirement, see n. 2, supra—hardly a sensible way to construe our precedents. Responding to these problems, Mr. Landor and the dis- sent submit that RLUIPA’s mere existence sufficed to alert the individual defendants, or at least their employer, that they could be held personally liable. See Brief for Petitioner 35; post, at 20. But, just like the attempt to rewrite Dole, this argument misses the point. A Spending Clause statute does not carry independent regulatory force. It assumes binding effect only through “voluntar[y] and knowin[g]” agreement. Pennhurst, 451 U. S., at 17. If someone has not agreed to be bound, it does not matter that he may be aware of the existence of a contract between other parties. And if someone has not agreed to be bound, it does not matter whether other contracting parties might wish to bind him. Either way, he has not agreed to be bound, so he cannot be.5 C Seeking still another way around the consent require- ment, Mr. Landor turns next to the fungibility of money. The individual defendants, he observes, receive paychecks from LDOC, and some of that entity’s funding comes from the federal government. As a result, Mr. Landor submits, the individual defendants are indirect recipients of federal funds and, for that reason, should be deemed to have im- plicitly consented to RLUIPA liability. —————— 5 The dissent also attempts a factual analogy to Dole, suggesting that, because Congress “use[d] its spending power to regulate . . . drinking habits” there, it is free to regulate the individual officers’ conduct here. Post, at 14. But this analogy fails for reasons we have seen. Under the spending legislation at issue in Dole, Congress conditioned federal high- way funds on an agreement by the States to exercise their regulatory powers to raise their drinking ages to 21. See 483 U. S., at 205, 211. Congress did not purport to regulate “drinking habits” directly, let alone create a federal cause of action against underage drinkers. Cite as: 609 U. S. ____ (2026) 13 Opinion of the Court This submission fails as well. Mr. Landor would have us hold, for the first time, that so long as a penny of federal spending makes its way to an individual, however indi- rectly, Congress can regulate his conduct directly based on the fiction that he has consented to regulation. None of that is consistent with our precedents holding that funding con- ditions in Spending Clause legislation lack independent regulatory force but instead derive their effect from “volun- tar[y] and knowin[g]” assent. Pennhurst, 451 U. S., at 17. Notice too where Mr. Landor’s theory would lead. Given the “explo[sion]” of Spending Clause legislation in recent decades, Medina, 606 U. S., at 373, Congress would enjoy an effectively unbridled police power. Federal authorities would have no need to show that their regulations repre- sent proper exercises of Congress’s limited and enumerated powers found in the Commerce Clause, the Bankruptcy Clause, or any other. All they would have to show is that a recipient who consented to a funding condition spent some formerly federal money in transactions with a third party. Just like that, the federal government could directly regu- late the third party’s conduct. Take some examples. On Mr. Landor’s theory, Congress could require coaches at uni- versities that receive federal funds to permit transgender athletes to play women’s sports—or face personal liability in suits for damages. Likewise, Congress could bar doctors at medical practices that accept federal funds from admin- istering certain vaccines to children—again on pain of dam- ages. See Tr. of Oral Arg. 37–43. None of that fits with our system of limited and enumerated federal powers where all others are reserved to the States and the people. The dissent criticizes us for “trot[ting] out” this “parade of horribles.” Post, at 24. But if this is a parade, the dissent marches right along, embracing these hypotheticals and more. See ibid. In fact, as the dissent sees it, we should not engage in “hairsplitting” over any “strict direct-consent- to-liability . . . requirement” or “ill-formed” contract 14 LANDOR v. LOUISIANA DEPT. OF CORRECTIONS AND PUBLIC SAFETY Opinion of the Court analogy. Post, at 17, 25. On its view, these things are all just “empt[y] . . . formalism[s].” Post, at 24. If Congress can ask individuals to consent to funding conditions—or ask States to enact laws in order to receive federal funds—Con- gress might as well be allowed to regulate private behavior directly. Ibid. Likely enough, that vision would have de- lighted Gouverneur Morris. But it is one at war with the terms of the Spending Clause, how that Clause has been widely understood since the founding, and a long line of this Court’s precedents. Nor is there anything “empty” about insisting that Congress operate within the limited and enu- merated powers the Constitution provides. This Court has rejected views like the dissent’s many times before. See Part II, supra. And we do so again today. Faced with that problem, Mr. Landor and the dissent search for some foothold in our precedents to support their view that the Spending Clause grants Congress direct reg- ulatory authority. Perhaps the best they can muster is a line snipped from Rust v. Sullivan, 500 U. S. 173 (1991), where we said that an individual employed in a federally funded program must “perform [his] duties in accordance with the . . . restrictions” specified by Congress. Id., at 198; Brief for Petitioner 32; post, at 24. But even that is of no help. Rust did not involve an attempt to impose personal liability on the program’s employees. The only consequence for violating Congress’s funding conditions fell on the fed- eral funding recipient itself and amounted to no more than a loss of funding. See 500 U. S., at 178–179. And that is exactly the “typical remedy” for noncompliance our cases have long described. Medina, 606 U. S., at 373 (internal quotation marks omitted). Mr. Landor and the dissent also point to Grove City Col- lege v. Bell, 465 U. S. 555 (1984), a Title IX case. Brief for Petitioner 32–33; post, at 15–16, n. 7. But there, too, the only penalty was the traditional one—the “terminati[on]” of federal funding. See Grove City College, 465 U. S., at 561. Cite as: 609 U. S. ____ (2026) 15 Opinion of the Court Subsequent events illustrate as much: After losing the case, the college decided “to exit the federal [funding] pro- grams rather than surrender its autonomy,” a choice it was free to make because Title IX binds only those who have freely elected to accept federal funds. Grove City College, Forty Years Ago, Supreme Court Case Changed GCC For- ever (Feb. 26, 2024) (archived at https://perma.cc/2AQU- 3PME). Pretty plainly, neither Rust nor Grove City College purported to reimagine the Spending Clause’s terms or to rewrite our precedents construing them.6 D Finding our precedents under the Spending Clause una- vailing, Mr. Landor and the dissent appeal to ones constru- ing the Necessary and Proper Clause. In Sabri v. United States, 541 U. S. 600 (2004), we held that Congress’s crimi- nal ban on theft, fraud, or bribery against a federal funding recipient, 18 U. S. C. §666, is a necessary and proper inci- dent to Congress’s authority under the Spending Clause. See 541 U. S., at 605–606; see also Salinas v. United States, 522 U. S. 52, 60–61 (1997). Mr. Landor and the dissent —————— 6 The dissent also resorts to a supposed concession. Respondents, the dissent says, concede “ ‘that Louisiana prison officials must comply with RLUIPA’s substantive protections.’ ” Post, at 17 (quoting Brief for Re- spondents 46). But the dissent omits the rest of the sentence, which clar- ifies that respondents concede only the possibility of “injunctive relief” against them “in their official capacities” for RLUIPA violations. Brief for Respondents 46 (emphasis added). And, of course, an “official capac- ity” suit is “no different from a suit against the State itself.” Printz v. United States, 521 U. S. 898, 931 (1997) (internal quotation marks omit- ted). Contrary to the dissent, respondents have clearly maintained all along that they cannot “be held personally liable for an alleged RLUIPA violation.” Brief for Respondents 46. The dissent is also wrong to sug- gest that any LDOC official who might be sued in his official capacity can for that reason be sued in his personal capacity. See post, at 18. The whole point of an official-capacity suit is that it “is not a suit against the official but rather is a suit against the official’s office.” Printz, 521 U. S., at 930–931 (internal quotation marks omitted). 16 LANDOR v. LOUISIANA DEPT. OF CORRECTIONS AND PUBLIC SAFETY Opinion of the Court contend this case is no different because personal liability for nonconsenting defendants is likewise a necessary and proper incident to RLUIPA’s policy protecting religious ex- ercises. Brief for Petitioner 36–39; post, at 15–20. Much as the other arguments we have encountered mis- conceive the Spending Clause, this one misunderstands the Necessary and Proper Clause. The latter provision author- izes Congress to employ “necessary and proper” means for “carrying into Execution” its other enumerated powers. Art. I, §8, cl. 18. Put another way, the Clause allows Con- gress to enact laws “incidental to those powers which are expressly given.” McCulloch v. Maryland, 4 Wheat. 316, 411 (1819). So the question is not, as Mr. Landor and the dissent would have it, whether a personal-capacity cause of action is incidental to RLUIPA’s policy protecting religious exercises. The question, instead, is whether their proposed cause of action is a necessary and proper incident to Con- gress’s constitutionally enumerated power to spend money. With the question correctly framed, the distinction be- tween this case and Sabri becomes unmistakable. Sec- tion 666 addresses thieves, fraudsters, bribers, and others who threaten to “fritte[r] away in graft” the funds Congress distributes pursuant to the Spending Clause. 541 U. S., at 605. The thief steals allocated money; the fraudster ex- tracts it under false pretenses; the briber obtains it by greasing palms. “Congress,” Sabri held, “does not have to sit by and accept the risk” actors of that sort pose to its con- stitutionally enumerated spending power. Ibid. Instead, as a necessary and proper incident to that power, Congress may punish people who seek to sap federal funds from their intended beneficiaries. See ibid. And Congress may do so, Sabri concluded, even where not every misappropriated dollar may be “ ‘traceabl[e]’ ” to “ ‘specific federal pay- ments.’ ” United States v. Comstock, 560 U. S. 126, 147 (2010) (quoting Sabri, 541 U. S., at 605–606). Cite as: 609 U. S. ____ (2026) 17 Opinion of the Court Nothing similar can be said for the cause of action Mr. Landor and the dissent propose. Suits against nonconsent- ing parties, like the individual officers here, might advance RLUIPA’s laudable policy of protecting religious exercises. But they do not safeguard from graft the federal funds Con- gress distributes pursuant to its spending power. Recogniz- ing as much, seemingly every Court of Appeals to address the question has concluded that Sabri does not begin to command the result Mr. Landor and the dissent seek. See Tripathy v. McKoy, 103 F. 4th 106, 115 (CA2 2024) (“Sabri is easily distinguishable”); Sharp v. Johnson, 669 F. 3d 144, 155, n. 15 (CA3 2012) (“Sabri is inapposite”); Haight v. Thompson, 763 F. 3d 554, 570 (CA6 2014) (“RLUIPA is nothing like the Sabri statute”); Barnett v. Short, 129 F. 4th 534, 543 (CA8 2025) (Sabri “is too dissimilar”); Wood v. Yordy, 753 F. 3d 899, 903 (CA9 2014) (reliance on Sabri is “not . . . sensible”). Nor, with Sabri out of the picture, can Mr. Landor and the dissent explain how their proposed cause of action would help “carr[y] into execution” Congress’s enumerated power to spend money. McCulloch, 4 Wheat., at 434. In truth, they don’t even try. Instead, they suggest, the Nec- essary and Proper Clause ought to be elastic enough to al- low the “extraction of money damages” from virtually any- one who violates virtually any condition found in Spending Clause legislation. Post, at 17–20, 24. But while the Nec- essary and Proper Clause may allow Congress to enact pro- visions actually incidental to its spending power, like those protecting federal money against graft, it does not tolerate outcomes that would “undermine the structure of [the fed- eral] government established by the Constitution.” Sebe- lius, 567 U. S., at 559 (opinion of ROBERTS, C. J.). Nor does the Clause tolerate results that would “violat[e] the princi- ple of state sovereignty.” Printz v. United States, 521 U. S. 898, 924 (1997). And adopting the expansive approach Mr. 18 LANDOR v. LOUISIANA DEPT. OF CORRECTIONS AND PUBLIC SAFETY Opinion of the Court Landor and the dissent propose would require us to violate both rules. Just consider what they would have us say. On their view, Congress may evade the consent requirement inher- ent in its Spending Clause authority simply by invoking the Necessary and Proper Clause. Post, at 17–20. With even a modest federal expenditure somewhere nearby, Congress could then proceed to regulate directly the conduct of count- less nonconsenting individuals—not just the individual of- ficers here, but also others like the coaches and physicians we discussed above. See Part III–C, supra. Congress could regulate directly, too, in innumerable spheres, including ones traditionally reserved to the States. Really, under Mr. Landor’s and the dissent’s logic, we would be “hard pressed to posit any activity . . . that Congress [would be] without power to regulate.” United States v. Lopez, 514 U. S. 549, 564 (1995). And as inconsistent as all that is with both principles of state sovereignty and a federal government of limited and enumerated regulatory powers, it hardly repre- sents a “proper means for carrying into [e]xecution” Con- gress’s spending power. Sebelius, 567 U. S., at 559 (opinion of ROBERTS, C. J.) (internal quotation marks and some al- terations omitted). * Under the Spending Clause, Congress’s power to spend money does not include the power to regulate. Spending Clause statutes can bind only those who voluntarily and knowingly undertake obligations by agreement with the federal government. Because that essential element is missing here, we affirm the judgment of the Fifth Circuit. It is so ordered. Cite as: 609 U. S. ____ (2026) 1 JACKSON, J., dissenting SUPREME COURT OF THE UNITED STATES _________________ No. 23–1197 _________________ DAMON LANDOR, PETITIONER v. LOUISIANA DEPARTMENT OF CORRECTIONS AND PUBLIC SAFETY, ET AL. ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT [June 23, 2026] JUSTICE JACKSON, with whom JUSTICE SOTOMAYOR and JUSTICE KAGAN join, dissenting. Congress enacted the Religious Land Use and Institu- tionalized Persons Act of 2000 (RLUIPA) to ensure that state and local prisons respect prisoners’ right to religious exercise. Congress might have opted to accomplish this through contracts with the prisons it funds. Instead, it passed a law. RLUIPA requires state and local prisons that accept fed- eral funding to accommodate prisoners’ religious exercise more generously than the Constitution mandates. Like many, this law comes with an enforcement mechanism: To ensure compliance, RLUIPA authorizes an impacted pris- oner to sue any prison employee who violates the statute. Such suits, the statute provides, may proceed against the employee in the employee’s individual capacity and may yield “appropriate relief.” 42 U. S. C. §§2000cc–2(a), 2000cc–5(4)(A). Neither respondents nor the Court contests Congress’s power to impose RLUIPA’s substantive directive accommo- dating religious freedom. The majority nevertheless adopts the peculiar position that Congress is powerless to create, and a State is powerless to accept, the natural next step: a damages remedy against officials who violate that directive. 2 LANDOR v. LOUISIANA DEPT. OF CORRECTIONS AND PUBLIC SAFETY JACKSON, J., dissenting This severance of rights and remedies is a sleight of hand; it comes by way of the majority’s full-throated endorsement of a contract analogy even though what secures the rights at issue is not a contract but a law. Today’s decision magi- cally transforms a federal statute into an invitation to be accepted or declined, deemed binding only if each particular defendant has explicitly agreed to be penalized. No matter that laws, as opposed to contracts, don’t ordinarily work this way. The trick here is the majority’s effortless confla- tion of law making and agreement making—two different sources of binding authority. The majority’s analysis is spellbindingly straightforward: Spending Clause statutes are contracts, and contracts bind only those who consent. Ante, at 6–8. But pulling this rab- bit out of the hat requires misconstruing the Spending Clause and the Necessary and Proper Clause, and ignoring decades of precedent affirming Congress’s authority to use the power of the purse to govern. In the end, the Court re- duces some of Congress’s greatest legislative achieve- ments—federal laws that secure civil rights, environmental stability, healthcare, and more—to nothing more than the wheelings-and-dealings of an especially wealthy private party. Because I would not so trivialize a federal statute or the constitutional powers pursuant to which it was passed, I respectfully dissent. I It is not often that a real-life incident so clearly illustrates Congress’s reasons for adopting legislation, or the Consti- tution’s wisdom in enabling it. Damon Landor’s Rastafarian faith requires him to “let the locks of the hair of his head grow.” The Holy Bible, Numbers 6:5 (King James Version). For a Rastafari like Landor, locks are “the physical embodiment of . . . spiritual identity and connection to God.” See Brief for Rastafari Scholars as Amici Curiae 3. Landor preserved this Cite as: 609 U. S. ____ (2026) 3 JACKSON, J., dissenting connection—through what is known as the Nazarite Vow— for two decades, allowing his hair to grow to his knees. And he continued for most of a brief stint in Louisiana jails in 2020: At the two facilities that housed Landor for the bulk of his prison time, officials accommodated his vow without incident. They did so not just because it was the right thing to do but also because federal law required it. This Court’s deci- sion in Holt v. Hobbs, 574 U. S. 352 (2015), held that RLUIPA mandated an accommodation for prisoners’ reli- giously motivated beards, id., at 369–370, and thus strongly suggested that Landor was entitled to a similar accommo- dation. Even more on point, the Fifth Circuit—which co- vers Louisiana—had precedent specifically requiring ac- commodation of the Nazarite Vow. See Ware v. Louisiana Dept. of Corrections, 866 F. 3d 263 (2017). Landor knew of Ware. He also knew of the threat that jails posed to his hair (and faith) despite it. So when he was transferred to a third jail with three weeks remaining in his sentence, he came prepared. He carried with him a copy— a physical, printed copy—of Ware. Upon arrival, Landor presented the case to the intake guard. “Unmoved,” the guard “threw Landor’s papers in the trash.” 82 F. 4th 337, 340 (CA5 2023) (case below). The guard summoned the warden, who demanded documentation from Landor’s sen- tencing judge corroborating his religious beliefs. “When Landor couldn’t instantly meet that demand, two guards carried him into another room, handcuffed him to a chair, held him down, and shaved his head.” Ibid. After serving his time, Landor sued the Louisiana De- partment of Corrections (LDOC), the jail, the warden, the department’s secretary, and John Doe officers 1–10 in their individual and official capacities. In addition to state-law claims, he brought claims under RLUIPA as well as under 42 U. S. C. §1983 for violations of his First, Eighth, and 4 LANDOR v. LOUISIANA DEPT. OF CORRECTIONS AND PUBLIC SAFETY JACKSON, J., dissenting Fourteenth Amendment rights, seeking both injunctive re- lief and damages. Respondents successfully moved to dismiss Landor’s com- plaint. Landor’s release from prison, the District Court ex- plained, mooted his bid for injunctive relief. Landor’s RLUIPA claim thus remained only by dint of his request for damages against the defendants in their individual capaci- ties. But Fifth Circuit precedent held that RLUIPA does not permit individual-capacity suits. See Sossamon v. Texas, 560 F. 3d 316, 327–329 (2009). With Landor’s re- maining claims failing for other reasons not relevant here, the District Court dismissed his complaint. Landor had federal law on his side. And he did every- thing he could do in real time to ensure that prison officials knew that. We took this case to address whether Landor can seek money damages from the officials who ignored the law, held him down, and “uncrowned him before God.” Brief for Rastafari Scholars as Amici Curiae 12. II Before us, respondents offer two reasons why Landor can- not obtain damages—one statutory and the other constitu- tional. First, they posit that RLUIPA’s provision for “ap- propriate relief ” against a “person acting under color of State law,” 42 U. S. C. §§2000cc–2(a), 2000cc–5(4)(A), au- thorizes only injunctive relief. Second, they assert that, if RLUIPA purports to authorize individual-capacity dam- ages lawsuits against prison officials, Congress will have exceeded the Constitution’s limits on its spending power. The majority addresses only the constitutional argument, giving short shrift to the “well-established principle . . . that normally the Court will not decide a constitutional question if there is some other ground upon which to dispose of the case.” Bond v. United States, 572 U. S. 844, 855 (2014) (in- ternal quotation marks omitted); see Ashwander v. TVA, 297 U. S. 288, 347 (1936) (Brandeis, J., concurring); Spector Cite as: 609 U. S. ____ (2026) 5 JACKSON, J., dissenting Motor Service, Inc. v. McLaughlin, 323 U. S. 101, 105 (1944) (calling this principle “more deeply rooted than any other in the process of constitutional adjudication”). The majority is of course correct that the practice is prudential, not inex- orable. Ante, at 4, n. 1. But there is prudence behind a prudential rule. The reasons for this one include “the deli- cacy” and “comparative finality” “of [the] function” of inval- idating a congressional enactment, and “the consideration due to the judgment of other repositories of constitutional power concerning the scope of their authority.” Rescue Army v. Municipal Court of Los Angeles, 331 U. S. 549, 571 (1947).1 So I begin by rejecting respondents’ statutory argument. RLUIPA plainly authorizes individual-capacity lawsuits for money damages. We have already interpreted identical language in RLUIPA’s sister statute, the Religious Free- dom Restoration Act of 1993 (RFRA), to allow for individ- ual-capacity damages lawsuits. See Tanzin v. Tanvir, 592 U. S. 43 (2020). And RLUIPA’s Spending Clause underpin- ning does not rob the statute’s text of its plain meaning. Understanding this is necessary background for Part III, infra, my response to the majority’s constitutional analysis. A RLUIPA is Congress’s latest contribution to a long-run- ning religious-liberty dialogue between Congress and this Court. That dialogue began, for our purposes, with Employ- ment Div., Dept. of Human Resources of Ore. v. Smith, 494 U. S. 872 (1990). Smith is a seminal case in which the —————— 1 I have no quarrel with the premise that a court may prioritize a con- stitutional question that is “readily resolved by our precedents” and “nar- rower” than the statutory alternative. Ante, at 4, n. 1. But the majority’s approach has neither virtue. As I will explain, if our precedents “readily resolv[e]” this case, they do so in Landor’s favor. And, while the conse- quences for RLUIPA are indeed narrower, the consequences for other Spending Clause statutes—not to mention congressional power more generally—are substantial. 6 LANDOR v. LOUISIANA DEPT. OF CORRECTIONS AND PUBLIC SAFETY JACKSON, J., dissenting Court held that the First Amendment does not carve out religious exemptions from neutral and generally applicable laws. Id., at 878–882. Smith “recognized, however, that the political branches could shield religious exercise through legislative accommodation.” Cutter v. Wilkinson, 544 U. S. 709, 714 (2005). Taking up the invitation, Con- gress sought to “restore” via statute what Smith left unpro- tected by the Constitution. Tanzin, 592 U. S., at 45. The result was RFRA, which forbade States and the Federal Government alike from substantially burdening religious exercise without compelling interest and narrow tailoring. See 42 U. S. C. §2000bb et seq. Importantly, RFRA was not meant to be merely advisory; like the constitutional rights it sought to imitate, RFRA needed bite. Thus, “RFRA made clear that it was reinstat- ing both the pre-Smith substantive protections of the First Amendment and the right to vindicate those protections by a claim.” Tanzin, 592 U. S., at 50. It did so by authorizing “appropriate relief ” for violations of its terms. §2000bb– 1(c). As enacted, RFRA applied to State and Federal Govern- ments and their officials. Tanzin, 592 U. S., at 50. But RFRA’s application to States and state officials was short lived: This Court would soon invalidate RFRA’s application to the States as exceeding Congress’s power under Section 5 of the Fourteenth Amendment. See City of Boerne v. Flo- res, 521 U. S. 507 (1997). Partially rebuffed, Congress tried again, enacting RLUIPA, 42 U. S. C. §2000cc et seq. In contrast to RFRA’s “sweeping” scope, RLUIPA focused in narrowly on two dis- crete “areas of state and local action” in which Congress thought religious freedom faced particular threat: land-use regulation and institutionalized persons. Sossamon v. Texas, 563 U. S. 277, 281 (2011). Other than the narrower coverage, RLUIPA practically mirrors RFRA, its “sister statute.” Ramirez v. Collier, 595 Cite as: 609 U. S. ____ (2026) 7 JACKSON, J., dissenting U. S. 411, 424 (2022). Like RFRA, RLUIPA aims to “secure redress” for “undue barriers” to religious exercise. Cutter, 544 U. S., at 716–717. Like RFRA, RLUIPA features “an express private cause of action” (indeed, one “that is taken from RFRA”). Sossamon, 563 U. S., at 282. And like RFRA’s, RLUIPA’s express cause of action allows “[a] per- son” who suffers a violation of the statute to “assert” the violation “as a claim or defense in a judicial proceeding and obtain appropriate relief against a government.” §§2000cc– 2(a), 2000bb–1(c). Though neither statute elaborates on what a plaintiff can get, both specify from whom they can get it. Neither stat- ute, that is, defines “appropriate relief.” But both define “government” to mean, among other things, an “official” of the relevant sovereign and any “other person acting under color of ” the relevant sovereign’s law. §§2000cc–5(4)(A), 2000bb–2(1). Thus, like RFRA, RLUIPA creates “a claim” for “appropriate relief against” an “official” or “other person acting under color of ” law. §§2000cc–2(a), 2000cc–5(4)(A), 2000bb–1(c), 2000bb–2(1). B As a matter of text, the question whether RLUIPA au- thorizes a claim for money damages is controlled by a unan- imous holding this Court issued just six Terms ago. In Tan- zin, 592 U. S. 43, we held that RFRA’s materially identical terms authorize a damages claim. Our analysis was straightforward. First, we ascertained the who. We iden- tified the potential defendants in a RFRA lawsuit, asking whether “injured parties can sue Government officials in their personal capacities.” Id., at 47. And to that question, we said that “RFRA’s text provides a clear answer: They can.” Ibid. RFRA authorizes lawsuits not just against a “government” as colloquially understood, but also against government “official[s]” and “other person[s] acting under color of law.” §§2000bb–1(c), 2000bb–2(1). This language, 8 LANDOR v. LOUISIANA DEPT. OF CORRECTIONS AND PUBLIC SAFETY JACKSON, J., dissenting we noted, echoes “one of the most well-known civil rights statutes: 42 U. S. C. §1983,” which authorizes individual- capacity lawsuits against “ ‘person[s]’ ” acting “ ‘under color of any statute.’ ” Tanzin, 592 U. S., at 48. With that answer in hand, we had no trouble discerning the what: “what ‘appropriate relief ’ entails.