A. Precedents Cited and How They Shaped the Decision
1. The Spending Clause as non-regulatory power
The majority’s constitutional foundation is drawn most prominently from Medina v. Planned Parenthood South Atlantic,
606 U. S. 357, especially its statement that the Spending Clause “does not ‘endow Congress with [any] power to regulate conduct.’”
The Court uses Medina to frame RLUIPA (as relevant here) not as direct regulation, but as a conditional-offer regime in which
obligations must rest on consent.
This framing also draws support from Cummings v. Premier Rehab Keller, 596 U. S. 212, which reiterates that Spending Clause
legislation “operates based on consent,” reinforcing the contract analogy and its consequences for remedies and liability.
2. Consent and the “contract analogy”
The centerpiece precedent is Pennhurst State School and Hospital v. Halderman, 451 U. S. 1, for two propositions:
(i) Spending Clause legislation is “much in the nature of a contract,” and (ii) “additional sanctions” beyond the typical funding remedy
require “voluntar[y] and knowin[g]” consent by those who must bear them.
The opinion situates Pennhurst within a long line of cases treating spending measures as compacts/agreements, including
Searight v. Stokes, 3 How. 151; Neil, Moore & Co. v. Ohio, 3 How. 720; McGee v. Mathis,
4 Wall. 143; and Steward Machine Co. v. Davis, 301 U. S. 548. This historical arc supplies the Court’s claim that consent is
not merely interpretive convenience but a constitutional necessity when Congress lacks independent regulatory authority.
3. Dole’s framework—and what the majority says it does not do
Landor relied heavily on South Dakota v. Dole, 483 U. S. 203, arguing his theory fit Dole’s requirements. The majority
counters that Dole’s prongs are additional constraints, not substitutes for consent. It emphasizes Dole’s discussion of coercion
(pressure vs compulsion) and Dole’s clear-statement principle as mechanisms to ensure genuine consent.
The majority thus reads Dole as aligned with Pennhurst rather than as an exhaustive checklist that would permit consent-free personal liability.
4. Coercion doctrine as a consent-protecting rule
The Court invokes National Federation of Independent Business v. Sebelius, 567 U. S. 519, to analogize Spending Clause consent
to contract assent: coercive offers (“gun to the head”) invalidate consent, reinforcing that consent must be real, not fictional.
5. RLUIPA’s Spending Clause pedigree
The opinion notes that the parties agree RLUIPA’s relevant provisions rest on the Spending Clause, and it cites Sossamon v. Texas,
563 U. S. 277, which recognized RLUIPA’s Spending Clause foundation. While Sossamon concerned sovereign immunity and damages against
a State, the majority leverages it for the broader proposition that the contract analogy is a “limitation on” liability under Spending Clause statutes.
6. Agency and contract law—rejected as a route to personal liability
Landor argued the officers, as LDOC agents, could be liable. The majority responds with standard agency/contract principles, citing
United States v. Gooding, 12 Wheat. 460, and Restatement (Second) of Agency §328, plus Hodgson v. Dexter, 1 Cranch 345,
for the proposition that a principal’s agents do not become liable to a third party for the principal’s contract nonperformance.
7. “Fungibility of money” and indirect-recipient theories—rejected
Landor’s claim that paychecks make officers “indirect recipients” of federal funds is rejected as incompatible with Pennhurst’s consent requirement.
The Court also warns that accepting this theory would effectively allow Congress to regulate private conduct wherever federal money can be traced,
producing an “unbridled police power” inconsistent with limited enumerated powers.
The majority distinguishes cases like Rust v. Sullivan, 500 U. S. 173, and Grove City College v. Bell, 465 U. S. 555,
emphasizing that those cases involved the traditional spending consequence—funding termination—rather than personal damages liability.
8. Necessary and Proper Clause and anti-corruption precedents—distinguished
Landor relied on Sabri v. United States, 541 U. S. 600 (and the opinion also cites Salinas v. United States, 522 U. S. 52),
where Congress criminalized bribery involving entities receiving federal funds as incidental to the spending power.
The majority distinguishes Sabri by reframing the inquiry: the question is not whether a damages action is incidental to RLUIPA’s policy (religious protection),
but whether it is incidental to Congress’s enumerated power to spend money. Sabri’s statute protected federal funds from being “frittered away in graft”;
personal-capacity RLUIPA suits, by contrast, do not protect the federal fisc in that way. The opinion also invokes United States v. Comstock,
560 U. S. 126, in describing Sabri’s tracing principle, but confines that logic to anti-graft measures.
9. Federalism guardrails
The majority’s broader federalism concerns are reinforced by citations to Printz v. United States, 521 U. S. 898, and
United States v. Lopez, 514 U. S. 549, to illustrate the structural danger of converting spending conditions into general regulatory authority.
10. Case-specific context: prison hair precedent
The opinion recounts Landor’s reliance on Ware v. LDOC, 866 F. 3d 263 (CA5 2017), which had held RLUIPA generally bars prisons
from cutting Rastafarians’ hair. Ware functions as factual backdrop (notice and alleged defiance), not as the doctrinal driver of the constitutional holding.