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