Doe v. Dynamic Physical Therapy, LLC, et al.
No. 25-180 · Decided December 8, 2025 · reversed and remanded
Whether a state statute immunizing healthcare providers from civil liability during public health emergencies can bar federal causes of action. A State has no power to confer immunity from federal causes of action.
ON PETITION FOR WRIT OF CERTIORARI TO THE COURT OF APPEAL OF LOUISIANA, FIRST CIRCUIT
Parties — Petitioner: DOE · Respondent: DYNAMIC PHYSICAL THERAPY, LLC, et al.
Vote & lineupPer Curiam
Who prevailed — The petitioner prevailed in that the judgment of the Louisiana Court of Appeal was reversed and the case was remanded.
The question

Whether a state statute immunizing healthcare providers from civil liability during public health emergencies can bar federal causes of action. Specifically, the Court addresses whether La. Rev. Stat. Ann. § 29:771(B)(2)(c)(i) can be used to block federal claims. The central issue is whether a State has the power to confer immunity from federal law.

Petitioner's argument
  • not stated
Respondent's argument
  • not stated
The decision
  • The Court held that the Louisiana Court of Appeal's decision was incorrect.
  • The Court reasoned that while a State has the prerogative to define the scope of liability under state law, it has no power to confer immunity from federal causes of action.
  • The Court relied on the Supremacy Clause of the U.S. Constitution, specifically U.S. Const., Art. VI, cl. 2.
  • The Court quoted U.S. Const., Art. VI, cl. 2, noting that "[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."
  • The Court cited *Howlett v. Rose*, 496 U. S. 356, 383 as authority for the principle that states cannot override federal law.
  • The Court further cited *Haywood v. Drown*, 556 U. S. 729, 740 and *Williams v. Reed*, 604 U. S. 168, 174.
  • The Court noted that the petitioner's federal claims may still fail on other federal grounds, citing *Cummings v. Premier Rehab Keller*, 596 U. S. 212, 222.
  • The Court concluded that any such determinations regarding federal grounds must be decided by the Louisiana courts in the first instance.
Read the full opinion on supremecourt.gov (PDF) →