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FNU Tanzin v. Tanvir

Facts

The respondents, Muhammad Tanvir, Jameel Algibhah, and Naveed Shinwari, are practicing Muslims who claimed that FBI agents placed them on the No Fly List in retaliation for their refusal to act as informants against their religious communities. They sued the agents in both their official and individual capacities, seeking removal from the No Fly List and money damages for the financial losses incurred due to their inability to fly. After the Department of Homeland Security allowed them to fly, the District Court dismissed their claims for monetary relief, but the Second Circuit reversed this decision.

Respondents Muhammad Tanvir, Jameel Algibhah, and Naveed Shinwari are practicing Muslims who claim that Federal Bureau of Investigation agents placed them on the No Fly List in retaliation for their refusal to act as informants against their religious communities.

Issue

Does the Religious Freedom Restoration Act (RFRA) permit litigants to obtain money damages against federal officials in their individual capacities?

The question here is whether 'appropriate relief' includes claims for money damages against Government officials in their individual capacities.

Rule

RFRA's express remedies provision allows individuals whose religious exercise has been unlawfully burdened to seek 'appropriate relief,' which includes money damages against federal officials acting in their individual capacities.

RFRAs text provides a clear answer: They can. Persons may sue and obtain relief 'against a government,' �00bb-1(c), which is defined to include 'a branch, department, agency, instrumentality, and official (or other person acting under color of law) of the United States.'

Analysis

The Court analyzed the statutory text of RFRA, concluding that the term 'government' includes officials acting under color of law, thus allowing for individual-capacity suits. The Court emphasized that the definition of 'appropriate relief' is open-ended and context-dependent, and that damages have historically been recognized as appropriate relief in suits against government officials. The Court also noted that RFRA reinstated protections that existed prior to the Smith decision, thereby allowing for claims for damages against government employees.

The Court analyzed the statutory text of RFRA, concluding that the term 'government' includes officials acting under color of law, thus allowing for individual-capacity suits. The Court emphasized that the definition of 'appropriate relief' is open-ended and context-dependent, and that damages have historically been recognized as appropriate relief in suits against government officials.

Conclusion

The Supreme Court affirmed the Second Circuit's ruling, holding that RFRA permits claims for money damages against federal officials in their individual capacities.

We hold that it does.

Who won?

The respondents prevailed in the case because the Supreme Court affirmed their right to seek damages under RFRA, recognizing the importance of protecting religious exercise from government interference.

The Second Circuit reversed. 894 F. 3d 449 (2018). It determined that RFRAs express remedies provision, combined with the statutory definition of 'Government,' authorizes claims against federal officials in their individual capacities.

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