DOE
v.
DYNAMIC PHYSICAL THERAPY, LLC
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The Supreme Court held that Louisiana's state statute immunizing healthcare providers from civil liability during public health emergencies cannot bar federal causes of action. States lack constitutional power to confer immunity from federal law, which is the supreme law of the land under the Supremacy Clause.
No. A state has no power to confer immunity from federal causes of action. While states may define the scope of liability under state law, they cannot use state immunity statutes to eliminate federal claims. The Supremacy Clause requires state judges to follow federal law notwithstanding contrary state law or constitutional provisions.
[1] A state cannot confer immunity from federal causes of action.
[2] The Supremacy Clause of the U.S. …
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Join FLexlaw to unlock all legal intelligence“a State has no power to confer immunity from federal causes of action”
The core holding establishing the constitutional principle that state immunity statutes cannot eliminate federal claims.
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Join FLexlaw to unlock all legal intelligenceLouisiana law immunizes healthcare providers from civil liability during public health emergencies. Plaintiff Doe brought federal claims against Dynam…
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Per Curiam DOE v. DYNAMIC PHYSICAL THERAPY, LLC, et al. certiorari to the court of appeal of louisiana, rst circuit No. 25–180. Decided December 8, 2025 The Louisiana Court of Appeal held that a Louisiana statute immunizing healthcare providers from civil liability barred plaintiff's federal claims. Held: The decision below was incorrect. A State has no power to confer immunity from federal causes of action.
U. S. Const., Art. VI, cl. 2; see also, e. g., Howlett v. Rose, 496 U. S. 356, 383; Haywood v. Drown, 556 U. S. 729, 740; Williams v. Reed, 604 U. S. 168, 174.
Certiorari granted; 2024–0723 (La. App. 1 Cir. 12/27/24), 404 So. 3d 1008, reversed and remanded. 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. Defning 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
It is so ordered.
Reporter’s Note The attached opinion has been revised to refect the usual publication and citation style of the United States Reports. The revised pagination makes available the official United States Reports citation in advance of publication. The syllabus has been prepared by the Reporter of Decisions for the convenience of the reader and constitutes no part of the opinion of the Court. Other revisions may include adjustments to formatting, captions, citation form, and any errant punctuation. The following additional edits were made: None
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Authorities Cited
- Howlett v. Rose, 496 U.S. 356 (U.S. 1990)
- Haywood v. Drown, 556 U.S. 729 (U.S. 2009)
- Williams v. Reed, 604 U.S. 168 (U.S. 2025)