Tanzin v. Tanvir
The Facts
Muhammad Tanvir and other Muslim men on the federal no-fly list alleged that FBI agents placed them on the list in retaliation for refusing to become informants, violating RFRA's protection of religious exercise. The Second Circuit held RFRA did not permit money damages against individual officials.
The Application
The Court applied RFRA's broad remedial language to the plaintiffs' circumstances, holding that federal agents' alleged retaliation against Muslim men for refusing to become informants constituted a substantial burden on religious exercise within the statute's protection. By interpreting "appropriate relief" to include money damages, the Court enabled Tanvir and others to pursue direct compensation from the individual FBI agents responsible for placing them on the no-fly list, rather than being confined to injunctive remedies or suits against the government as an entity. The decision turned on statutory text rather than common-law frameworks that prior circuit precedent had grafted onto RFRA, making clear that individual-capacity damages claims posed no sovereign immunity barrier and fit squarely within Congress's remedial scheme.
The Conclusion
**Unanimous ruling for Tanvir.** Thomas wrote the majority. RFRA authorizes damages against individual federal officials, expanding the statute's remedial reach beyond injunctive relief.
No circuit court data for this case.
Case Analysis
Overview
The Supreme Court held unanimously that the Religious Freedom Restoration Act permits suits for money damages against individual federal officials in their personal capacities, overturning circuit precedent that had read RFRA to authorize only injunctive relief.
Facts
Muhammad Tanvir and other Muslim men on the federal no-fly list alleged that FBI agents placed them on the list in retaliation for refusing to become informants, violating RFRA's protection of religious exercise. The Second Circuit held RFRA did not permit money damages against individual officials.
Issue
Whether the Religious Freedom Restoration Act authorizes claims for money damages against federal officials in their individual capacities.
Rule
RFRA provides a cause of action against the government broadly and, by its text, authorizes 'appropriate relief' including money damages; individual-capacity suits fall within the statute's scope because they do not conflict with sovereign immunity principles applicable to suits against the United States itself.
Analysis
The Court applied RFRA's broad remedial language to the plaintiffs' circumstances, holding that federal agents' alleged retaliation against Muslim men for refusing to become informants constituted a substantial burden on religious exercise within the statute's protection. By interpreting "appropriate relief" to include money damages, the Court enabled Tanvir and others to pursue direct compensation from the individual FBI agents responsible for placing them on the no-fly list, rather than being confined to injunctive remedies or suits against the government as an entity. The decision turned on statutory text rather than common-law frameworks that prior circuit precedent had grafted onto RFRA, making clear that individual-capacity damages claims posed no sovereign immunity barrier and fit squarely within Congress's remedial scheme.
Conclusion
**Unanimous ruling for Tanvir.** Thomas wrote the majority. RFRA authorizes damages against individual federal officials, expanding the statute's remedial reach beyond injunctive relief.
Notes
OT2020. Added via SCOTUS bulk import 2026-05-14
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