U.S. Supreme Court: Texas protected from monetary damages by sovereign immunity in prisoner's religious freedom lawsuit
WASHINGTON – Texas prison keepers interfered with Harvey Sossamon's exercise of religion, but the state doesn't owe him a cent, the U. S. Supreme Court ruled on April 20.
Six Justices found sovereign immunity protects Texas from a claim for money damages under the federal Religious Land Use and Institutionalized Persons Act of 2000.
Sossamon sought a cash award after officials mooted his lawsuit by allowing group worship in the chapel and preserving worship privileges for those under discipline.
He argued that when states accept federal money, they subject themselves to traditional remedies for breach of contract, including compensatory damages.
The Court, however, held that waiver of sovereign immunity can't be implied.
Justice Clarence Thomas wrote that "applying ordinary contract principles here would make little sense because contracts with a sovereign are unique."
He wrote, "Sossamon's implied contract remedies proposal cannot be squared with our long standing rule that a waiver of sovereign immunity must be expressly and unequivocally stated in the text of the relevant statute."
Chief Justice John Roberts and Justices Antonin Scalia, Anthony Kennedy, Ruth Bader Ginsburg, and Samuel Alito agreed.
Dissenting Justices Sonia Sotomayor and Stephen Breyer wrote that the majority erected a barrier to vindication of rights Congress deliberately provided.
Sotomayor wrote, "It is difficult to believe that Congress would have devoted such care and effort to establishing significant statutory protections for religious exercise and specifically extended those protections to persons in state institutions, yet withheld from plaintiffs a crucial tool for securing the rights the statute guarantees."
She wrote, "Injunctive relief from a federal court may address a violation going forward, but this fact will be of cold comfort to the victims of serious, non-recurring violations for which equitable relief may be inappropriate."
According to Thomas, Sossamon is an inmate in the Robertson Unit of the Texas Department of Criminal Justice.
In 2006, he sued the state and individual prison officials in federal court at Austin.
He alleged he qualified for injunctive relief and money damages under the Act, which provides "appropriate relief" for violations.
District Judge Sam Sparks entered summary judgment against money damages in 2007, and Fifth Circuit appeals judges in New Orleans affirmed him in 2009.
Sossamon fared no better in Washington.
Thomas wrote, "Upon ratification of the Constitution, the states entered the Union with their sovereignty intact."
He wrote that immunity from private suits is central to sovereign dignity.
A state may choose to waive immunity in federal court at its pleasure, he wrote, but the test for determining whether a state waived it is a stringent one.
"The requirement of a clear statement in the text of the statute ensures that Congress has specifically considered state sovereign immunity and has intentionally legislated on the matter," he wrote.
"Without such a clear statement from Congress and notice to the states, federal courts may not step in and abrogate state sovereign immunity," he wrote.
Sotomayor found it self evident that "appropriate relief" included money damages.
"Under general remedies principles, the usual remedy for a violation of a legal right is damages," she wrote.
"By adopting a contrary reading of the term, the majority severely undermines the broad protection of religious exercise Congress intended the statute to provide," she wrote.
She found no reason why appropriate relief would provide adequate notice as to equitable remedies but not as to monetary ones.
Scott Medlock and James Harringtobn, both of Texas Civil Rights Project in Austin, represented Sossamon.
Attorney General Greg Abbott represented Texas.