Back in Tanzin v. Tanvir, 592 U. S. ____ (2020), the U.S. Supreme Court unanimously held that the Religious Freedom Restoration Act of 1993’s (RFRA) state remedies supply authorizes litigants, when appropriate, to acquire money damages against federal officials in their individual skills for separating litigants’ right to free exercise of religion under the First Amendment. Even the Court’s decision clears the way for Muslims put to the”No Fly List” to chase money compensation from a group of FBI agents in their private capacity.
Facts of the Case
The Religious Freedom Restoration Act of 1993 (RFRA) prohibits the Federal Government from imposing substantial burdens on religious exercise, absent a compelling interest pursued through the least restrictive means. Additionally, it gives a person whose religious exercise was burdened the right to find”appropriate relief.” The RFRA sought to offset the effect of the holding and restore the pre-Smith”compelling interest test” by”provid[ing] a claim… to persons whose religious exercise is substantially burdened by government.”
Respondents Muhammad Tanvir, Jameel Algibhah, and Naveed Shinwari are practicing Muslims who claim that FBI agents put them over the No Fly List in retaliation for their refusal to act as informants from their spiritual communities. Respondents sued different representatives in their official capacities, seeking removal from the No Fly List. They also resisted the representatives in their individual capacities for cash. Based on respondents, the retaliation price them considerable sums of cash: airline tickets squandered and earnings from job opportunities lost.
More than a year after respondents suedthe Department of Homeland Security advised them they could now flythus mooting the claims for injunctive relief. The District Court then dismissed the individual-capacity claims for money damages, judgment that RFRA does not permit monetary relief. The Second Circuit Court of Appeals reversed. It determined that RFRA’s express remedies supply, combined with the statutory definition of”Government,” prides claims against government officials in their individual capacities. Determined by our precedent and RFRA’s broad protections for religious liberty, the court concluded that the open-ended term”appropriate relief” encompasses cash damages against officials.
Supreme Court’s Conclusion
With a vote of 8-0, the Supreme Court confirmed. “We conclude that RFRA’s state remedies provision allows litigants, when appropriate, to acquire money damages against federal officials in their individual capacities,” Justice Clarence Thomas wrote on behalf of their unanimous Court.
Justice Thomas initially addressed if wounded parties may sue Government officials in their personal capacities. In answering in the positive, Justice Thomas cited the plain language of the statute, composing:
RFRA’s text gives a clear answer: They could. Persons can sue and get relief”from a government,” §2000bb–1(c), which is defined to contain”a branch, division, agency, instrumentality, and official (or other individual acting under color of law) of the USA.” §2000bb–2(1) (emphasis added).
Since Justice Thomas explained, below the RFRA’s definition, the relief which may be implemented from an”official… of the Unites States” has been”relief from a government.” He further noted that this interpretation has been supported by RFRA’s use of the term”persons acting under color of law,” which has been interpreted by this Court in the 42 U.S.C. §1983 circumstance to permit suits against officials in their individual capacities.
Justice Thomas then turned to if the”appropriate relief” referenced in the RFRA allows for monetary compensation. Rejecting the government’s argument, the Court maintained that it will. “A damages remedy is not only’proper’ relief as viewed through the lens of lawsuits against Government workers,” he also wrote. “It’s is also the only form of relief which can remedy some RFRA violations. For specific injuries, such as economists’ wasted plane tickets, effective relief is composed of compensation, not even an injunction.”
The Court rejected the administration’s argument that it ought to be careful of harms against government officials since these awards could raise separation-of-powers concerns. “But there are no inherent reasons why people have to do this in its stead.”
The article SCOTUS Rules Litigants May Spartan Federal Officials Individually in Religious Freedom Suits appeared on Constitutional Law Reporter.