Yesterday in
Webman v. Federal Bureau of Prisons, (DC Cir., March 28, 2006), the U.S. Court of Appeals for the DC Circuit held that damages are not an available remedy for individuals suing under the Religious Freedom Restoration Act. It held that
RFRA's authorization of "appropriate relief against a government" did not waive the federal government's sovereign immunity against damage claims. This is the first circuit court opinion directly dealing with the issue.