The case of Landor v. La. Dep’t of Corr. & Pub. Safety, No. 23-1197, slip op. (U.S. June 23, 2026) sits at the intersection of federal funding law and religious liberty in prisons. At its core, the dispute concerns the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), a federal statute passed under Congress’s Spending Clause power. RLUIPA says that when states accept federal funds for prisons, they must not substantially burden an incarcerated person’s religious exercise unless the restriction is the least restrictive means of furthering a compelling governmental interest.

Damon Landor, a Rastafarian prisoner, alleges that prison officials violated his religious beliefs by forcibly shaving his head despite knowing that his faith required him to keep his hair uncut. According to Landor, when he was transferred to another prison near the end of his sentence, he provided the new officers with a copy of an order protecting his religious practice. He alleges that the officers disregarded the order, discarded it, and cut his hair anyway. For Landor, the violation was not simply a disagreement over prison policy; it involved the loss of a religious practice that he believed was central to his faith. He sued under RLUIPA, seeking relief against both the Louisiana Department of Corrections and the individual prison officers in their personal capacities.

The key legal question before the Supreme Court was whether RLUIPA’s Spending Clause framework allows prisoners to seek monetary damages from individual state officers who themselves were not parties to the federal funding “agreement.”

The Court said no. It held that Spending Clause laws operate in a contract-like way between the federal government and the state agency receiving the money — in this case, the state prison system. Because the individual officers were not parties to that funding arrangement and never personally agreed to accept RLUIPA’s conditions, they could not be treated as bound by those conditions.

Therefore, the Court held that individual officers cannot be sued in their personal capacities under RLUIPA. Additionally, Landor sought monetary damages from the officers in their personal capacities, the practical effect of the decision was that he could not obtain damages from those individual officers under RLUIPA. However, the Court’s holding was not limited to the type of remedy requested; it was based on whether RLUIPA created a personal claim against officers who never consented to the federal funding conditions.

The Court rejected the argument that officers are bound by RLUIPA simply because they work for a state agency that receives federal funds. It also rejected the argument that Congress could rely on the Necessary and Proper Clause to impose personal liability on individuals who never agreed to the statute’s conditions. The Court reasoned that allowing such liability would extend the Spending Clause beyond its constitutional limits by treating individuals as bound by conditions they never accepted. In the majority’s view, this would blur the distinction between regulating a state institution that receives federal funds and directly imposing obligations on individual state employees.

From a broader constitutional perspective, the majority takes a narrower view of federal power under the Spending Clause. It emphasizes consent, structure, and the idea that obligations created through federal funding programs apply only to those who are parties to the funding arrangement. The dissent, by contrast, views this approach as an unnecessary restriction on Congress’s ability to create effective enforcement mechanisms for civil rights laws. Justice Jackson, joined by Justices Sotomayor and Kagan, argues that federal statutes are laws enacted by Congress, not private contracts, and therefore bind state actors through constitutional authority rather than individual consent. She also warns that without the ability to seek relief against individual officers, prisoners may be left without an effective remedy when the harm has already occurred.

This difference in approach has important implications for future federal programs that rely on funding conditions to protect individual rights within state institutions. The majority’s reasoning suggests that courts may closely examine whether Congress has clearly identified who may be held liable when it uses the Spending Clause. Future disputes may focus not simply on the obligations attached to federal funding, but on whether Congress has constitutional authority to impose personal liability on individuals who were not participants in the funding agreement.

Although Landor involved religious rights in prisons, the case offers a broader lesson that may also be relevant to Arizona's HB4117, that would create a criminal offense for intentionally interfering with a religious service or religious activity. One important lesson from Landor is that the legal framework courts use to interpret a statute can significantly affect the scope of the rights, obligations, and remedies created by that law. In Landor, the majority interpreted RLUIPA through the lens of Spending Clause consent and contract principles, while the dissent viewed the statute as a congressional command that binds government actors through federal law.

Similarly, courts interpreting HB4117 may view the statute through different interpretive lenses. One approach would focus on protecting religious services conducted at places of worship. Another could focus more broadly on protecting individuals engaged in religious activity. Depending on which framework a court adopts, the statute could be applied more narrowly to disruptions of worship services or more broadly to conduct such as public prayer or religious demonstrations, reflecting concerns raised by opponents of the bill.

That principle may become important when interpreting HB4117 because the bill refers to “religious service or religious activity” but does not define the full scope of what qualifies as a protected religious activity. Although the statute limits the offense to conduct that occurs in connection with a place of religious worship and requires intentional interference, questions may still arise about how broadly courts should understand the phrase “religious activity.” A court could view the statute primarily as protecting religious services and places of worship from disruption.

Alternatively, a court could interpret the statute more broadly as protecting individuals engaged in religious activity. The choice between these approaches could affect whether the statute applies only to disruptions of organized worship services or extends to other forms of religious expression, such as public prayer or religious demonstrations.

The lack of a precise definition may lead to disputes about the statute’s scope. Opponents of the bill have argued that broader interpretations could protect conduct beyond what they believe the legislature intended or what the First Amendment allows. Whether those interpretations would succeed depend on the statutory text and the rules of statutory construction courts apply, including consideration of the plain language of the statute and, if ambiguity remains, possible evidence of legislative intent.