Sossamon v. Texas, 131 S. Ct. 1651

Sossamon, an inmate in Texas, sued the State of Texas and prison officials under RLUIPA's private right of action seeking injunctive and monetary relief.
RLUIPA §3 applies to substantial burdens on religious exercise where federal funds are involved in land-use or institutionalized settings.
The district court granted summary judgment, holding sovereign immunity barred monetary relief against Texas.
Fifth Circuit affirmed, holding that RLUIPA's private damages relief was not an unequivocal waiver of immunity by accepting federal funds.
The issue before the Supreme Court was whether states consent to monetary damages under RLUIPA by accepting federal funding.
Majority held that 'appropriate relief' does not unambiguously include damages, so immunity remains intact and damages are barred.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does 'appropriate relief' in RLUIPA authorize damages against states?	Sossamon argues it includes damages under Wells-Franklin Barnes precedents.	Texas contends 'appropriate relief' is ambiguous and does not unambiguously waive immunity for damages.	No; damages not unambiguously included.
Does Spending Clause funding constitute clear notice of a damages waiver?	Sossamon asserts Spending Clause funds imply a damages waiver.	Texas argues no explicit waiver; general Spending Clause context does not imply damages.	No clear notice; waiver not shown.
Does § 1003's residual clause in the Rehabilitation Act Amendments extend to RLUIPA damages?	Sossamon contends residual clause waives immunity for §3, including damages.	Texas argues §3 is not a 'statute prohibiting discrimination' and thus not within §1003 residual clause.	Residual clause does not clearly extend to §3; no waiver.

Pennhurst State School and Hospital v. Halderman, 451 U.S. 1 (1981) (waiver must be express and unequivocal)
Atascadero State Hospital v. Scanlon, 473 U.S. 234 (1985) (clear statement required for waiver of immunity)
College Savings Bank v. Florida Prepaid Postsecondary Ed. Expense Bd., 527 U.S. 666 (1999) (strict construction; consent must be unequivocal)
Lane v. Peña, 518 U.S. 187 (1996) (waiver construed in favor of sovereign)
Nordic Village, Inc. v. United States, 503 U.S. 30 (1992) (ambiguity prevents imposing monetary liability on the Government)
Franklin v. Gwinnett County Public Schools, 503 U.S. 60 (1992) (presumption of available remedies unless Congress says otherwise)
Barnes v. Gorman, 536 U.S. 181 (2002) (appropriately broad remedies include damages unless limited by statute)
Davis v. Monroe County Bd. of Ed., 526 U.S. 629 (1999) (spending power can authorize private damages actions)
Gebser v. Lago Vista Independent School Dist., 524 U.S. 274 (1998) (damages under statutory conditions; context of private rights)
West v. Gibson, 527 U.S. 212 (1999) (appropriateness of remedies disputed; related discussion on damages)
Spector v. Norwegian Cruise Line Ltd., 545 U.S. 119 (2005) (clarity of congressional intent and waiver requirements)