Tanzin v. Tanvir

In Tanzin v. Tanvir, three Muslim men lawfully residing in the United States alleged that FBI agents placed them on the federal No Fly List as retaliation for refusing to become informants and spy on their own religious communities. The plaintiffs sued the agents in their individual capacities under the Religious Freedom Restoration Act, seeking monetary damages for lost jobs, wasted travel expenses, and severe emotional distress. The District Court dismissed the damages claims, holding that RFRA does not authorize monetary relief. The Second Circuit reversed, and the Supreme Court granted certiorari. On December 10, 2020, the Supreme Court unanimously ruled that RFRA's express remedies provision permits litigants to obtain money damages against federal officials in their individual capacities.

The Supreme Court unanimously (8-0) held that RFRA's express remedies provision permits litigants, when appropriate, to obtain money damages against federal officials in their individual capacities. Justice Thomas authored the opinion. Justice Barrett took no part in the decision. The Court affirmed the Second Circuit. However, on remand, the District Court granted qualified immunity to the defendants in February 2023, and the Second Circuit affirmed the dismissal in October 2024.

Whether the Religious Freedom Restoration Act of 1993, 42 U.S.C. § 2000bb, permits lawsuits seeking money damages against individual federal employees.

The ruling marked a significant victory for American Muslims and religious liberty advocates, establishing that federal officials can be held personally liable for violations of religious freedom. It aligned conservative Christian groups and Muslim communities in support of broad religious rights protections. The decision also reinforced the historical principle that damages are a necessary mechanism for government accountability. However, the subsequent qualified immunity rulings limited the practical effect for the plaintiffs, while the Second Circuit clarified that coercing individuals to become informants by placing them on the No Fly List would violate RFRA.