Doe v. Dynamic Physical Therapy, LLC

Summary

Because a State lacks the power to confer immunity from federal causes of action, the Louisiana Court of Appeal’s judgment that a plaintiff’s federal claims are barred by a Louisiana statute immunizing health care providers from civil liability during public health emergencies is reversed.

Text

PRELIMINARY PRINT 
Volume 607 U. S. Part 1 
Pages 11–12 
OFFICIAL REPORTS 
OF 
THE SUPREME COURT 
December 8, 2025 
REBECCA A. WOMELDORF 
reporter of decisions 
Page Proof Pending Publication
NOTICE: This preliminary print is subject to formal revision before 
the bound volume is published. Users are requested to notify the Reporter 
of Decisions, Supreme Court of the United States, Washington, D. C. 20543, 
[email protected], of any typographical or other formal errors.

OCTOBER TERM, 2025 11 
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 liabil-
ity 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 fed-
eral 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 notwith-
standing.” 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 de-
cide in the frst instance. The petition for certiorari is 
granted, the judgment of the Louisiana Court of Appeal is 
Page Proof Pending Publication

12 DOE v. DYNAMIC PHYSICAL THERAPY, LLC 
Per Curiam 
reversed, and the case is remanded for further proceedings 
not inconsistent with this opinion. 
It is so ordered. 
Page Proof Pending Publication

Page Proof Pending Publication
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 offcial 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, cap-
tions, citation form, and any errant punctuation. The following additional 
edits were made: 
None

Retrieval chunks

• #1

  PRELIMINARY PRINT Volume 607 U. S. Part 1 Pages 11–12 OFFICIAL REPORTS OF THE SUPREME COURT December 8, 2025 REBECCA A. WOMELDORF reporter of decisions Page Proof Pending Publication NOTICE: This preliminary print is subject to formal revision before the bound volume is published. Users are requested to not…

• #2

  reversed, and the case is remanded for further proceedings not inconsistent with this opinion. It is so ordered. Page Proof Pending Publication Page Proof Pending Publication Reporter’s Note The attached opinion has been revised to refect the usual publication and citation style of the United States Reports. Th…