Does the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA) permit plaintiffs to sue nonconsenting state employees in their personal capacities for damages? Specifically, can individuals be held liable under a Spending Clause statute if they have not voluntarily and knowingly consented to such liability? Finally, does the Necessary and Proper Clause authorize such a cause of action as an incident to the spending power?

• Individual officers are agents of the Louisiana Department of Corrections (LDOC) and should be held personally liable under agency law principles, citing *Restatement (Second) of Agency §385(1)*.
• The proposed cause of action satisfies the four requirements for Spending Clause legislation established in *South Dakota v. Dole*.
• The individual defendants are indirect recipients of federal funds because they receive paychecks from LDOC, which implies their consent to RLUIPA liability.
• A personal-capacity cause of action is a necessary and proper incident to RLUIPA's policy of protecting religious exercises under the Necessary and Proper Clause, relying on *Sabri v. United States*.

• Individual officers were not parties to the agreement between LDOC and the federal government to answer private suits under RLUIPA.
• RLUIPA does not permit suits against officers in their individual capacities because they did not voluntarily and knowingly consent to such liability.
• The provision for "appropriate relief" under 42 U. S. C. §§2000cc–2(a), 2000cc–5(4)(A) authorizes only injunctive relief, not money damages.

• The Court held that individuals may not be held liable in their personal capacities under a Spending Clause statute unless those individuals have voluntarily and knowingly consented to answer lawsuits under the statute.
• The Court relied on the "Spending Clause" (Art. I, §8, cl. 1), noting that while it allows Congress to spend for the general welfare, it does not "endow Congress with [any] power to regulate conduct."
• Applying a "contract analogy," the Court reasoned that sanctions beyond the termination of federal funds are permissible only with the "voluntar[y] and knowin[g]" consent of those who must bear them, citing *Pennhurst State School and Hospital v. Halderman*.
• The Court rejected the agency law argument, stating that under *Restatement (Second) of Agency §328*, a principal's agents do not become liable to a third party for the principal's nonperformance of a contract.
• The Court clarified that the four requirements in *South Dakota v. Dole* apply in addition to—not instead of—the rule that Congress may not bind individuals without their knowing and voluntary consent.
• The Court dismissed the "fungibility of money" argument, ruling that indirect receipt of funds via paychecks does not constitute consent and would grant Congress an unbridled police power inconsistent with the Spending Clause.
• The Court found the Necessary and Proper Clause (Art. I, §8, cl. 18) inapplicable, distinguishing *Sabri v. United States* because the current case involves policy enforcement rather than safeguarding federal funds from being "frittered away in graft."
• The Court concluded that because the individual officers never formed an agreement with the federal government, the case cannot proceed against them.