Sossamon v. Texas, 563 U.S. 277

Question whether states’ acceptance of federal funds constitutes waiver of sovereign immunity to monetary damages under RLUIPA.
RLUIPA provides a private right of action for ‘appropriate relief’ against governments that receive federal funds.
Sossamon, an inmate, sued Texas under RLUIPA for injunctive and monetary relief based on prison policies affecting religious exercise.
District court and Fifth Circuit held monetary claims barred by state sovereign immunity; relied on the text of § 2000cc-2(a).
Court held that ‘appropriate relief’ is not unambiguously damages, so no clear waiver of immunity; damages not available against the State.
Court reaffirmed that waiver of sovereign immunity must be explicit and unequivocal in the relevant statute.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does RLUIPA’s private remedy authorize monetary damages against states?	Sossamon argues ‘appropriate relief’ includes damages against states.	Texas argues the phrase is ambiguous and does not unambiguously include damages.	Damages not unambiguously included; no waiver.
Does Spending Clause context give states notice of damages liability?	Spending Clause implies broader liability for fund recipients.	No clear textual warning; waiver must be explicit.	Not explicit; no notice of damages liability.
Does § 1003 of the Rehabilitation Act Amendments provide a residual waiver of sovereign immunity for RLUIPA damages?	Residual clause could reach § 3 of RLUIPA to permit damages.	Residual clause does not clearly reach ‘substantial burden’ provisions.	Residual clause does not unequivocally extend to § 3; no damages waiver.
Do Franklin and Barnes help show that ‘appropriate relief’ includes damages for an express damages waiver?	Those precedents imply damages are available when there is no explicit limitation.	Those cases involve nonsovereign defendants; not controlling for sovereign immunity.	Not controlling here; no clear textual waiver of damages.

Seminole Tribe of Fla. v. Florida, 517 U.S. 44 (1996) (sovereign immunity bars private suits against unconsenting states)
College Savings Bank v. Florida Prepaid Postsecondary Ed. Expense Bd., 527 U.S. 666 (1999) (clear statement rule for waivers of state sovereign immunity)
Atascadero State Hospital v. Scanlon, 473 U.S. 234 (1985) (strictly construed waivers; iterative context for state consent)
Lane v. Peña, 518 U.S. 187 (1996) (unequivocal expression principle in waiver of immunity)
Pennhurst State School and Hospital v. Halderman, 465 U.S. 89 (1984) (Immunity limitations; textual unequivocal waiver required)
Franklin v. Gwinnett County Public Schools, 503 U.S. 60 (1992) (presumption of available remedies unless explicitly limited)
Barnes v. Gorman, 536 U.S. 181 (2002) (appropriate relief includes damages absent explicit limitation)
Nordic Village, Inc. v. United States, 503 U.S. 30 (1992) (ambiguous waivers should not be interpreted to impose monetary liability)
West v. Gibson, 527 U.S. 212 (1999) (explicitly discussed scope of 'appropriate relief' and damages)