free exercise of religion

Sossamon v. Texas

Issues

Whether the term “appropriate relief” as provided in the Religious Land Use and Institutionalized Persons Act should be interpreted to include monetary damages or instead should be interpreted to include only injunctive and declaratory relief?

 

Harvey Leroy Sossamon, III is an inmate at a Texas state prison. The prison warden refused to allow cell-restricted inmates to attend religious services and denied all inmates use of the prison chapel for religious purposes. In 2006, Sossamon filed suit against the State of Texas and various state and prison officials, alleging that the Texas prison violated the Religious Land Use and Institutionalized Persons Act ("RLUIPA"). Sossamon sought declaratory and injunctive relief, as well as compensatory and punitive damages. The District Court granted summary judgment in favor of Texas, holding that Texas has sovereign immunity under the 11th Amendment and is not liable for damages. The Fifth Circuit affirmed. Sossamon argues here that the words “appropriate relief,” as provided by RLUIPA, unambiguously waives the state's immunity from damages. Texas counters that “appropriate relief” does not amount to clear notice which is required before a state may waive its sovereign immunity. The Supreme Court’s decision in this case will determine the protection afforded to states under RLUIPA and may deter states from implementing policies which violate the Act.

Questions as Framed for the Court by the Parties

Whether an individual may sue a state or state official in his official capacity for damages for violations of the Religious Land Use and Institutionalized Persons Act, 42 U.S.C. §2000cc et seq. (2000 ed.).

Petitioner Harvey Leroy Sossamon, III has been an inmate of the Robertson Unit of the Correctional Institutions Division of the Texas Department of Criminal Justice since 2002. See Brief of Respondents, Texas et al.

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