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The Religious Freedom Restoration Act of 1993 prohibits the federal government from imposing substantial burdens on religious exercise, absent a compelling interest pursued through the least restrictive means. It also gives a person whose religious exercise has been unlawfully burdened the right to seek appropriate relief. "Appropriate relief" includes claims for money damages against government officials in their individual capacities.
Respondents were practicing Muslims who sued under the Religious Freedom Restoration Act of 1993 (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 district court found that the RFRA did not permit monetary relief and dismissed their individual-capacity claims. The Second Circuit reversed, holding that RFRA's remedies provision encompassed money damages against Government officials.
Did the RFRA’s remedies provision encompass money damages against Government officials?
The Court held that RFRA's express remedies provision permitted litigants, when appropriate, to obtain money damages against federal officials in their individual capacities. Under RFRA's definition, relief that can be executed against an "official of the United States" was relief against a government. Given that RFRA reinstated pre-Smith protections and rights, parties suing under RFRA must have at least the same avenues for relief against officials that they would have had before Smith. That means RFRA provided, as one avenue for relief, a right to seek damages against government employees.