Justia Opinion Summary and Annotations

The Religious Freedom Restoration Act of 1993 (RFRA) provides a remedy to redress federal government violations of the right to free exercise under the First Amendment. Practicing Muslims sued under RFRA, claiming that federal agents placed them on the No Fly List for refusing to act as informants against their religious communities. They sought injunctive relief against the agents in their official capacities and monetary damages against the agents in their individual capacities.

The Supreme Court affirmed the Second Circuit in holding that RFRA’s express remedies provision permits litigants, when appropriate, to obtain money damages against federal officials in their individual capacities. RFRA’s text provides that persons may “obtain appropriate relief against a government,” including an “official (or other person acting under color of law) of the United States,” 42 U.S.C. 2000bb–2(1). RFRA supplants the ordinary meaning of “government” with an express definition that includes “official[s]” and underscores that “official[s]” are “person[s].” Under RFRA’s definition, relief that can be executed against an “official . . . of the United States” is “relief against a government.” What relief is “appropriate” is context-dependent. In the context of suits against government officials, damages have long been awarded as appropriate relief. Damages are available under section 1983 for clearly established violations of the First Amendment; that means RFRA provides, as one avenue for relief, a right to seek damages against government employees.

Annotation

Primary Holding

The Religious Freedom Restoration Act permits litigants, when appropriate, to obtain money damages against federal officials in their individual capacities.