Doe v. Dynamic Physical Therapy, LLC, 607 U.S. ___ (2025)

Docket No. 25-180
Decided: December 8, 2025
Justia Summary

The Louisiana Court of Appeal ruled that a Louisiana law immunizing healthcare providers from civil liability during public health emergencies barred federal claims. The U.S. Supreme Court reversed this decision, ruling that a state cannot confer immunity from federal causes of action. The case was remanded for further proceedings.


Annotation
Primary Holding

A state has no power to confer immunity from federal causes of action.


Opinions
SUPREME COURT OF THE UNITED STATES

JOHN DOE v. DYNAMIC PHYSICAL THERAPY, LLC, et al.

on petition for writ of certiorari to the court of appeal of louisiana, first circuit

No. 25–180. Decided December 8, 2025

Per Curiam.

Louisiana immunizes healthcare providers from civil liability during public health emergencies. La. Rev. Stat. Ann. §29:771(B)(2)(c)(i) (West 2022). Below, the Louisiana Court of Appeal held that this state statute barred plaintiff’s federal claims. 2024–0723, pp. 11–12 (1 Cir. 12/27/24), 404 So. 3d 1008, 1017–1018, writ denied, 2025–00105 (La. 4/29/25), 407 So. 3d 623. That decision is incorrect. Defining the scope of liability under state law is the State’s prerogative. But a State has no power to confer immunity from federal causes of action. See, e.g., Howlett v. Rose, 496 U.S. 356, 383 (1990); Haywood v. Drown, 556 U.S. 729, 740 (2009); Williams v. Reed, 604 U.S. 168, 174 (2025). “[T]he Judges in every State” are bound to follow federal law, “any Thing in the Constitution or Laws of any state to the Contrary notwithstanding.” U. S. Const., Art. VI, cl. 2.

Plaintiff’s federal claims may well fail on other federal grounds. Cf. Cummings v. Premier Rehab Keller, 596 U.S. 212, 222 (2022). But that is for the Louisiana courts to decide in the first instance. The petition for certiorari is granted, the judgment of the Louisiana Court of Appeal is reversed, and the case is remanded for further proceedings not inconsistent with this opinion.

It is so ordered.


Materials
Jan 9, 2026 Judgment and Mandate Issued.
Dec 8, 2025 Petition GRANTED. Judgment REVERSED and case REMANDED for further proceedings not inconsistent with the Opinion of the Court. Opinion per curiam. (Detached Opinion)
Dec 1, 2025 DISTRIBUTED for Conference of 12/5/2025.
Nov 17, 2025 DISTRIBUTED for Conference of 11/21/2025.
Oct 29, 2025 DISTRIBUTED for Conference of 11/14/2025.
Oct 14, 2025 Brief of respondents Dynamic Physical Therapy, LLC, et al. in opposition filed.
Sep 11, 2025 Motion to extend the time to file a response is granted and the time is extended to and including October 15, 2025.
Sep 5, 2025 Motion to extend the time to file a response from September 15, 2025 to October 15, 2025, submitted to The Clerk.
Jul 28, 2025 Petition for a writ of certiorari filed. (Response due September 15, 2025)