Sossamon v. Texas

PETITIONER: Harvey Leroy Sossamon, III
RESPONDENT: Texas, et al.
LOCATION: United States District Court for the Middle District of Florida, Tampa Division

DOCKET NO.: 08-1438
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Fifth Circuit

CITATION: 563 US 277 (2011)
GRANTED: May 24, 2010
ARGUED: Nov 02, 2010
DECIDED: Apr 20, 2011

James C. Ho - Solicitor General of Texas, for the respondents
Kevin K. Russell - for the petitioner
Sarah E. Harrington - Assistant to the Solicitor General, Department of Justice, for the United States as amicus curiae supporting the petitioner

Facts of the case

Harvey Sossamon, a Texas inmate, sued the state of Texas and various state officials in their official and individual capacities in a Texas federal district court. In part, he argued that he was denied access to the prison's chapel and religious services in violation of the Religious Land Use and Institutionalized Persons Act ("RLUIPA"). The district court dismissed the claim.

On appeal, the U.S. Court of Appeals for the Fifth Circuit held that Mr. Sossamon could not sue Texas officials in their individual capacities under the RLUIPA. The court reasoned that because the Act was passed pursuant to Congress' Spending Power and not its Fourteenth Amendment Power, it did not create a cause of action for damages against state officials sued in their individual capacities.


Under the RLUIPA, can a person sue a state official in his individual capacity for damages?

Media for Sossamon v. Texas

Audio Transcription for Oral Argument - November 02, 2010 in Sossamon v. Texas

Audio Transcription for Opinion Announcement - April 20, 2011 in Sossamon v. Texas

Clarence Thomas:

This case comes to us on the writ of certiorari to the United States Court of Appeals from the Fifth Circuit.

According to the Religious Land Use and Institutionalized Persons Act of 2000, prisons that received that received federal funding may not impose a substantial burden on prisoner's religious exercise unless that burden is in furtherance of a compelling governmental interest.

An issue in this case is the Act's private cause of action which allows a plaintiff to obtain "an appropriate relief against a Government."

Petitioner Harvey Sossamon is a Texas inmate.

He sued State of Texas and various prisoner officials under this private cause of action and sought money damages.

The District Court granted some rejudgement for the defendants, holding that sovereign immunity barred Sossamon's claims for damages against the State and its officials.

The Court of Appeals for the Fifth Circuit affirmed.

And an opinion filed with the clerk today, we affirm the judgment of the Court of Appeals. And accepting federal funding, Texas did not consent to waive its sovereign immunity to suits for money damages under the Act.

Our precedents require that waivers of sovereign immunity be unequivocally expressed in the text of the relevant statute and strictly construed in favor of the sovereign.

The Act's authorization of appropriate relief against a Government is not being equivocal expressed -- unequivocal expression of state consent to monetary claims that our precedents require, nor does Section 1003 of the Rehabilitation Act Amendments of 1986, independently put the State on notice that it could be sued for the damages under the Act.

Justice Sotomayor has filed a dissenting opinion in which Justice Breyer joins.

Justice Kagan took no part in the consideration or decision of this case.