Does the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA) permit a plaintiff to sue individual state employees in their personal capacities for money damages? Specifically, can such liability be imposed on individuals who have not personally entered into an agreement with the federal government? The case asks whether the Spending Clause allows Congress to bind nonconsenting individuals to the conditions attached to federal funds.

• Individual officers should be held liable under agency law because they are agents of the Louisiana Department of Corrections (LDOC) and have a "duty to obey all reasonable directions" from their principal.
• The proposed cause of action satisfies the four requirements for Spending Clause legislation established in *South Dakota v. Dole*.
• Because individual officers receive paychecks derived from federal funds, they are indirect recipients who have implicitly consented to RLUIPA liability through the fungibility of money.
• Under the Necessary and Proper Clause and the reasoning in *Sabri v. United States*, personal liability is a necessary and proper incident to the policy of protecting religious exercises.

• While LDOC may have agreed to answer certain private suits as a condition of federal funding, the individual officers were not parties to that agreement.
• RLUIPA does not permit suits against state officers in their individual capacities.
• The petitioner has failed to allege that the individual defendants voluntarily and knowingly consented to face personal liability under RLUIPA.

• Individuals cannot be held liable in their personal capacities under a Spending Clause statute unless they have "voluntar[y] and knowin[g]" consent to answer lawsuits under that statute.
• The Court relies on the Constitution's 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" directly (*Medina v. Planned Parenthood South Atlantic*).
• To determine if a spending condition is enforceable, the Court applies a "contract analogy," ensuring conditions apply only to those who knowingly and voluntarily agreed to them (*Pennhurst State School and Hospital v. Halderman*).
• The Court rejects the agency law argument, stating that under blackletter contract law, a principal's agents do not become liable to a third party for the principal's nonperformance (Restatement (Second) of Agency § 328; *Hodgson v. Dexter*).
• The Court clarifies that the four prongs of *South Dakota v. Dole* apply in addition to—not instead of—the requirement of voluntary and knowing consent.
• The "fungibility of money" argument is rejected because allowing indirect receipt of funds to constitute consent would grant Congress an "unbridled police power" inconsistent with a government of limited and enumerated powers.
• Regarding the Necessary and Proper Clause (Art. I, § 8, cl. 18), the Court holds that the relevant question is whether the cause of action is incidental to the *power to spend*, not the policy goal; unlike in *Sabri v. United States*, these suits do not safeguard federal funds from being "frittered away in graft."