In today's episode, we analyze the Supreme Court's recent activities across three key areas:
- Last week's 11 opinions and emerging patterns
- Term statistics and remaining docket overview
- Major religious liberty case granted certiorari via June 23rd Order List
Key Topics Covered
Term Statistics (As of June 23, 2025)
- Total cases heard: 62 unique cases this term
- Cases decided: 52 (approximately 84%)
- Cases pending: 11 (approximately 16%)
- Methodology: Consolidated cases counted once
Last Week's Opinion Analysis
- Unanimous consensus: 7 of 11 cases showed stable coalition of seven justices
- Opinion distribution: Justice Thomas, Sotomayor, Gorsuch, and Barrett each authored exactly 4 opinions
- Chief Justice Roberts: Finally joined dissent after 41 consecutive majority opinions
- Methodological splits: Justices divided on simple textual approaches vs. complex multi-factor tests
Featured Case Deep Dive: Esteras v. United States
- Issue: Whether judges can consider retribution in supervised release decisions
- Majority (Barrett): Applied "expressio unius" canon - Congress deliberately excluded retribution
- Dissent (Alito/Gorsuch): Criticized majority's "mind-bending exercises" for trial judges
- Vote: 7-2 with additional splintering on implementation details
Standing Doctrine Analysis: FDA v. Reynolds & Diamond Energy v. EPA
- Common thread: When can businesses challenge regulations affecting market participants?
- Identical 7-2 splits with completely different reasoning approaches
- Barrett's approach: Traditional statutory interpretation and precedent analysis
- Kavanaugh's approach: Practical economic reasoning and regulatory dynamics
Certiorari Grant: Landor v. Louisiana Department of Corrections | Case No. 23-1197 | Docket Link: Here.
- Question Presented: Whether the Religious Land Use and Institutionalized Persons Act (RLUIPA) permits individual-capacity damages suits against state prison officials who violate prisoners' religious exercise rights.
The Shocking Facts
- Petitioner: Damon Landor, devout Rastafarian with 20-year religious dreadlocks
- Incident: Prison officials threw away Fifth Circuit decision protecting his rights, then forcibly shaved his head
- Timeline: Occurred with just 3 weeks left in his sentence
- Legal precedent: Clear violation of Ware v. Louisiana Department of Corrections
Legal Framework
- RFRA (1993): Applies to federal government; Tanzin v. Tanvir (2020) permits individual damages
- RLUIPA (2000): Applies to state/local governments receiving federal funds
- Sister statutes: Nearly identical language and purposes
- Circuit split: All courts of appeals currently reject RLUIPA individual damages
Petitioner’s (Landor) Key Arguments:
- Tanzin controls: Identical "appropriate relief" language must have same meaning
- Sister statute harmony: Supreme Court routinely interprets RFRA/RLUIPAtogether
- Constitutional authority: Spending Clause permits individual liability under Dole test
- Practical necessity: Damages often only meaningful remedy for released prisoners
Respondent’s (Louisiana) Key Arguments:
- No circuit split: Unanimous rejection across all circuits
- Spending Clause limits: Only grant recipients (states) can be liable, not individual officials
- Sossamon precedent: "Appropriate relief" is "ambiguous" under RLUIPA
- Practical concerns: Would worsen prison staffing crisis and destabilize Title IX law
United States Key Arguments:
- Supports petitioner - significant federal government backing
- Argues Sossamon only addressed sovereign immunity, not individual officials
- Emphasizes Congress's clear Spending Clause authority
Remaining Docket Highlights
Constitutional Powder Kegs
- Trump v. Casa trilogy: Immigration enforcement and nationwide injunctions
- Free Speech Coalition v. Paxton: Online adult content restrictions vs. child protection
Voting Rights Crucible
- Louisiana v. Callais: Racial gerrymandering vs. Voting Rights Act compliance
Religious Liberty Battleground
- Mahmoud v. Taylor: Religious exercise vs. LGBTQ+ curricula in schools
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