So, about that Rastafarian (Mr. Lindor)...
First, let me just be really clear about one thing. I hope to God those prison guards have long since been fired and never work in anything within 100 miles of law enforcement again.
But having looked at the decision, I can sorta now see how they came out the way did, and that 'way' reflects an emerging theme that is going to be important in other contexts. So by way of background, the suit was filed against the state and the guards in their personal capacities under the Religious land use and institutionalized persons act, which is supposed to protect religious rights of prisoners. The act was authorized solely under the spending clause, however, and authorizes lawsuits for money against recipients of federal funds who violate the rights of prisoners. So far, so good.
Here, Mr. Lindor originally sued both the state and the guards, but for reasons that aren't stated (perhaps a settlement), he dropped his claims against the state and went solely against the guards in their personal capacity. Where it gets interesting is that in prior cases, the court has said that for statutes authorized solely under the spending clause, lawsuits for money as a remedy can only be allowed if the defendant has consented to suit (usually, by accepting the money). Here, the guards are not federal grant recipients, the state was, and in the absence of consent they therefore couldn't otherwise be sued for money in their personal capacity.
And that's the broader interesting piece...courts (mostly, to date, lower courts) have been toying around with this theme of 'spending clause laws are different' (and rightfully so given the constitutional history which is relatively clear that it wasn't a carte blanche authorization to regulate beyond the other enumerated powers). In my world, the interesting case I'm watching, relating to drug pricing, is whether state laws are subject to more aggressive preemption if they attach changes that upset the bargain set in a federal spending power program. I suspect they won't, but that's teed' up in the fourth circuit.
