Doe v. Dynamic Physical Therapy, LLC | Docket

Doe v. Dynamic Physical Therapy, LLC

The Louisiana Court of Appeal held that Louisiana’s healthcare-provider immunity statute barred John Doe’s federal claims arising from a public health emergency. The Supreme Court held that a State may define liability under state law but cannot confer immunity from federal causes of action, reversed the judgment, and remanded for the Louisiana courts to consider other possible federal grounds.

Docket

Court

Supreme Court of the United States

Court level

supreme

Jurisdiction

Federal

Date filed

December 8, 2025

Parties

Dynamic Physical Therapy, LLC · defendantJohn Doe · plaintiff

Status

published

Disposition

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.

Opinion type

combined

Format

per curiam

Source

View PDF

Cite as: 607 U. S. ____ (2025)

Per Curiam

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.