No Individual-Capacity Damages Under RLUIPA After Tanzin: Sixth Circuit Reaffirms Spending Clause Clear-Statement Rule and Clarifies Redressability for Prison Diet Claims

Introduction

This published decision from the U.S. Court of Appeals for the Sixth Circuit addresses a recurring and consequential question at the intersection of prisoners’ religious exercise, the remedial scope of RLUIPA, and the practicalities of prison diet accommodations. In Fathiree Uddin Ali v. Stephen E. Adamson, a Muslim inmate sought a halal diet that, by his religious lights, must include halal meat and exclude haram foods. After a prison chaplain directed him to the Michigan Department of Corrections’ (MDOC) vegan diet program as the entry point for accommodation, the Special Activities Coordinator denied his vegan request upon learning that Ali had recently purchased substantial quantities of haram items from the commissary. Ali sued under RLUIPA, the Free Exercise Clause, and 42 U.S.C. § 1983, naming the chaplain, the Special Activities Coordinator, the warden, and MDOC.

The district court dismissed the claim against MDOC and granted summary judgment to the individual officials. Writing for the panel, Chief Judge Sutton dismisses parts of the appeal for lack of jurisdiction (mootness/redressability) and affirms in all other respects. The opinion squarely reaffirms that, notwithstanding the Supreme Court’s decision in Tanzin v. Tanvir, RLUIPA does not authorize money damages against state officials in either their official or individual capacities—because RLUIPA is a Spending Clause statute that triggers a clear-statement requirement not present in RFRA. The court also clarifies the proper defendants for injunctive relief, the effect of prison transfers on redressability, the substantial-burden threshold under RLUIPA for diet claims, and the application of qualified immunity to Free Exercise damages claims based on commissary purchases.

Summary of the Opinion

• Jurisdiction and Mootness:
  • Injunctive claims against the chaplain (Adamson) and warden (Jackson) are not redressable: under MDOC policy, only the Special Activities Coordinator may approve vegan diets and only the Deputy Director may approve custom alternative menus; neither the chaplain nor the warden can grant the requested relief. Ali’s transfer to a different facility also moots claims against those officials at his former prison.
  • Injunctive relief under § 1983 against the Special Activities Coordinator (Leach) is moot because he was sued only in his individual capacity and later left state employment; an injunction against a former employee would be advisory.
• RLUIPA Remedies:
  • No money damages under RLUIPA against state officials in either official or individual capacities. Haight v. Thompson remains controlling; Tanzin v. Tanvir does not abrogate it because RFRA and RLUIPA rest on different constitutional foundations.
• RLUIPA Merits (Injunctive/Declaratory):
  • Claim against Leach fails because Ali did not show a “substantial burden” on his religious exercise: he could apply (and re-apply annually) for the vegan menu, request an alternative menu if vegan is inadequate, and purchase halal items from the commissary.
  • Claim against MDOC fails because Ali did not identify a Department policy that substantially burdens religion; to the contrary, MDOC’s policies are accommodating.
• Free Exercise (§ 1983) Damages and Qualified Immunity:
  • Chaplain Adamson: No clearly established violation for asking Ali to pursue the vegan menu before requesting a custom alternative; he recommended Ali for the vegan diet and did not “single out” his religious practice.
  • Special Activities Coordinator Leach: No clearly established violation in denying a vegan diet where the applicant had purchased substantial haram items, especially given prior Sixth Circuit approvals of revoking religious diets based on noncompliant purchases.
• Disposition: Appeal dismissed in part for lack of jurisdiction; otherwise affirmed.

Analysis

Precedents Cited and Their Influence

• Article III and Mootness: Lujan v. Defenders of Wildlife (injury, causation, redressability) furnishes the constitutional baseline; Brown v. Yost (6th Cir. 2024) reinforces that mootness extinguishes jurisdiction when relief is no longer effectual. These guide the dismissal of injunctive claims where the named officials lack authority or have left office, particularly after an inmate’s transfer.
• § 1983 “Person” and Individual/Official Capacity: Will v. Michigan Dept. of State Police bars damages against states and state officials in their official capacities under § 1983, framing why Leach could only be sued individually and why an injunction against an individual who has left office is moot.
• RLUIPA Remedies and the Spending Clause:
  • Sossamon v. Texas: “Appropriate relief” is ambiguous; no damages against states under RLUIPA.
  • Haight v. Thompson (6th Cir.): No damages against state officials in individual capacities under RLUIPA; Spending Clause clear-statement rule governs.
  • Tanzin v. Tanvir: RFRA permits damages against federal officials—but RFRA’s basis (enforcement of constraints on the federal government and Fourteenth Amendment origins pre-Boerne) differs from RLUIPA’s Spending Clause footing, so Tanzin’s reading does not carry over.
  • Pennhurst, South Dakota v. Dole, Arlington Central: Spending Clause conditions must be unambiguous; this animates the court’s insistence on an unmistakably clear damages authorization in RLUIPA—which is absent.
  • District of Columbia v. Carter: Same words can vary in scope depending on constitutional source; supports divergent readings of “appropriate relief” in RFRA vs. RLUIPA.
  • NFIB v. Sebelius: Spending power can implement policies beyond enumerated powers if states knowingly accept conditions; clarity protects state choice.
  • Post-Tanzin circuit consensus: Landor (5th Cir.), Tripathy (2d Cir.), Fuqua (9th Cir.) reaffirm no individual-capacity damages under RLUIPA, aligning with the Sixth Circuit’s reaffirmation here; Mack (3d Cir.) predates Tanzin but likewise distinguishes RFRA and RLUIPA.
• RLUIPA Substantial Burden and Accommodation:
  • Holt v. Hobbs and Cavin v. MDOC: Threshold requirements—sincerity and substantial burden—must be met before triggering the “daunting” strict scrutiny inquiry.
  • New Doe Child #1: “Substantial burden” exists when prisoners are forced to choose between faith and serious penalties; this frames why ready alternatives mitigate burden.
  • Haight (merits): “Barring access” to foods essential to a religious rite can be a substantial burden; the court distinguishes Ali’s circumstances because access existed via vegan and commissary options and the ability to re-apply.
• Free Exercise and Qualified Immunity:
  • Turner v. Safley and Shaw v. Murphy: Deference to prison administration under Free Exercise unless policies target and substantially burden sincere beliefs; sets the general standard but requires specificity for “clearly established” law.
  • Colvin v. Caruso: Right to an adequate diet consistent with religious beliefs, while noting that overly rigid zero-tolerance policies may be problematic in some contexts.
  • Saucier v. Katz, Ashcroft v. al-Kidd, and Moore v. Oakland County (6th Cir. 2025): Clearly established law demands on-point precedent; broad principles do not suffice.
  • Berryman v. Granholm, Russell v. Wilkinson, and Miles v. MDOC: Approving revocation of religious diets when inmates possess or purchase noncompliant food; supports reasonableness of denying or rescinding accommodations based on commissary behavior.
  • Mbonyunkiza v. Beasley (8th Cir.): De minimis disruptions do not amount to substantial burdens—a compatible principle in diet cases.
  • Heyerman v. County of Calhoun and Hays v. Jefferson County: § 1983 liability is individual; one official is not liable for another’s unconstitutional act without authorization or acquiescence.
  • Ewing v. Finco (6th Cir. order): Unpublished, not precedential, and factually distinguishable.

Legal Reasoning

The court’s reasoning proceeds in four steps: jurisdiction, RLUIPA remedies, RLUIPA merits, and Free Exercise qualified immunity.

1) Jurisdiction and Redressability

Article III requires a concrete injury that is likely to be redressed by a favorable court decision. Under MDOC policy, only the Special Activities Coordinator can approve vegan diets and only the Deputy Director can approve alternative menus that include meats. The chaplain and warden at Ali’s former prison lack that authority, and his transfer to a different facility renders any injunctive relief against them ineffectual. As to Leach, the Special Activities Coordinator, Ali sued only in an individual capacity, and Leach no longer works for MDOC; an injunction against a departed individual does not produce effectual relief and therefore is moot. This redressability analysis channels injunctive claims toward current officials with actual authority over the requested accommodation.

2) RLUIPA Damages: “Appropriate Relief” in Spending Clause Context

The court reaffirms that RLUIPA does not authorize money damages against state officials (either officially or individually). RLUIPA is Spending Clause legislation: it conditions federal funds to states on compliance with specified requirements, which must be stated unambiguously to ensure states knowingly consent. The phrase “appropriate relief” is inherently context-dependent and ambiguous; without unmistakable clarity from Congress, it cannot be read to expose states or state officials to damages in private suits.

While RFRA uses the same phrase, Tanzin upheld damages against federal officials under RFRA in a wholly different constitutional context. Congress does not need special authority to regulate the federal government’s own operations; nor does RFRA’s application to federal officers rely on Spending Clause bargains with clear terms. The court therefore refuses to “graft” Tanzin’s RFRA remedy onto RLUIPA’s Spending Clause regime. The opinion reinforces a broad, post-Tanzin circuit consensus that the remedy scopes diverge because the constitutional sources diverge.

3) RLUIPA Merits: No Substantial Burden on This Record

RLUIPA prohibits substantial burdens on religious exercise unless the government employs the least restrictive means to further a compelling interest. But the plaintiff must first show sincerity and a substantial burden before any strict scrutiny applies. Here, the court finds no substantial burden because:

• MDOC offers a vegan menu designed to comply with halal principles and to avoid cross-contamination with haram meat.
• Ali could re-apply annually for the vegan diet and, if inadequate, request an alternative menu that might include halal meat, subject to Deputy Director approval.
• Ali could purchase halal items (including halal sausages) from the commissary, and the record shows he had the means and did so.

Given these options—especially the ability to re-apply after the 2017 denial—the court sees no coercive dilemma forcing Ali to violate his beliefs under threat of serious consequences. This also distinguishes Haight, which addressed concrete “barring” of necessary religious foods for a specific rite; Ali’s access paths remained open.

4) RLUIPA Claim Against MDOC as an Entity: No Policy-Level Violation

RLUIPA liability requires showing that a “government” imposed a substantial burden. MDOC’s written policies do not burden religion; they are designed to accommodate religious diets through vegan menus and alternative-menu requests, and to facilitate transfers where needed. Ali’s grievance targets the denial of his particular application by a single official, not a Department-level policy. Without a policy that burdened his religious exercise, the RLUIPA claim against MDOC fails at the pleading stage.

5) Free Exercise Damages and Qualified Immunity

Qualified immunity requires (1) a constitutional violation and (2) that the right was clearly established. The court resolves the cases against both Adamson and Leach at least on the second prong.

• Chaplain Adamson: He recommended Ali for the vegan diet and merely asked Ali to pursue the standard sequential process (vegan first, then alternative). There is no clearly established law that such a procedural step “singles out” or substantially burdens religion. Nor can Adamson be held liable for Leach’s denial absent authorization or acquiescence, which was not shown.
• Coordinator Leach: Denying a vegan-diet application based on extensive haram commissary purchases did not violate clearly established law. Sixth Circuit cases have approved rescinding religious diets where inmates buy or possess noncompliant items. The denial-versus-revocation distinction does not change the qualified-immunity analysis, especially without on-point precedent showing that denial on these facts is unconstitutional.

Impact

• Remedial Landscape Under RLUIPA in the Sixth Circuit: This opinion cements that damages are not available against state officials under RLUIPA in this circuit, even after Tanzin. Prisoner-plaintiffs must target prospective injunctive or declaratory relief, directed at current officials with actual authority to grant religious diet accommodations (e.g., Special Activities Coordinators or Deputy Directors in their official capacities).
• Pleading and Proof Strategies for Religious Diet Claims:
  • Identify an actual policy that imposes the burden—or show that available policies are illusory in practice. Merely challenging one-off application denials may not suffice to establish government-imposed burdens at the entity level.
  • Document the absence of “ready alternatives.” Evidence that the vegan program fails to meet religious tenets, that alternative-menu requests are unavailable or illusory, or that commissary halal options are financially impracticable may be critical to show a substantial burden.
  • Commissary behavior matters. Purchases of noncompliant foods can undermine sincerity and support denials or revocations; inmates should expect scrutiny of commissary records in religious diet litigation.
• Jurisdictional Hygiene: Plaintiffs must sue the right officials for prospective relief and account for transfers. An injunction must run against a current official who can implement the relief systemwide or at the new facility.
• Qualified Immunity in the Prison Context: General Free Exercise principles are not enough. Plaintiffs must cite on-point precedent that squarely governs the specific circumstances. Here, the Sixth Circuit’s own cases on revoking religious diets due to noncompliant purchases made it reasonable to deny a diet based on similar conduct.
• National Alignment: The Sixth Circuit’s reaffirmation aligns with the Second, Fifth, Ninth, and Third Circuits in reading RLUIPA’s “appropriate relief” more narrowly than RFRA’s, due to the Spending Clause’s clear-statement rule. This cross-circuit harmony reduces the likelihood of successful certiorari bids premised on a remedial split.

Complex Concepts Simplified

• Spending Clause and Clear-Statement Rule: When Congress conditions federal money to states (the Spending Clause), it must state its terms plainly so states know the consequences of accepting the funds. Courts will not infer big liabilities—like money damages—unless Congress speaks with unmistakable clarity.
• RFRA vs. RLUIPA: Both protect religious exercise, but they sit on different constitutional foundations. RFRA restricts federal officials directly; RLUIPA binds states only through the Spending Clause’s consent-based mechanism. Hence the same words—“appropriate relief”—can mean different things, with RLUIPA’s version not including damages against state officials.
• Redressability and Mootness: Even with a valid claim, courts can act only if a judgment will likely fix the injury. Suing an official who lacks authority—or who has left their job—won’t yield effective relief; such claims are dismissed as moot.
• Official vs. Individual Capacity: Suing an official in their “official capacity” is essentially suing the office and is suited to prospective relief. “Individual capacity” targets personal liability, typically for damages. Under § 1983, states and state officials in their official capacities are not “persons” for damages claims.
• Substantial Burden (RLUIPA): A substantial burden arises when the government effectively forces a believer to violate religious tenets under threat of serious consequences. If the prison provides viable religious-compliant options (e.g., vegan meals, the ability to request alternatives, affordable commissary items), the burden may not be “substantial.”
• Qualified Immunity: Even if an official errs, they are immune from damages unless they violate a right that was clearly established for the specific situation. Broad principles or different fact patterns will not overcome qualified immunity.

Conclusion

Ali’s case clarifies several important doctrinal and practical points. Most prominently, the Sixth Circuit reaffirms that RLUIPA’s “appropriate relief” does not include money damages against state officials in individual capacities, notwithstanding Tanzin’s reading of RFRA. That conclusion flows from RLUIPA’s Spending Clause foundation and the clear-statement rule. On the merits, the court underscores that religious diet claims require a threshold showing of a substantial burden; the existence of functioning vegan menus, the ability to re-apply and request alternatives, and the availability of commissary halal items undercut such a showing on this record.

For future litigants, the decision highlights the importance of targeting the correct officials for prospective relief, substantiating the absence or inadequacy of available accommodations, and avoiding commissary conduct that compromises claims of sincerity. For corrections systems, it confirms that well-structured, accessible diet programs—together with fair processes for re-application and reasoned consideration of commissary behavior—are both legally defensible and operationally prudent.

In short, the opinion fortifies the boundary between RFRA and RLUIPA remedies, tightens the jurisdictional and merits filters for religious diet claims, and illustrates the demanding “clearly established” standard that shields prison officials from damages in close Free Exercise cases.