Docket 25-180
Doe v. Dynamic Physical Therapy LLC
DecidedDec 8, 2025
Per Curiamdecision
Source: CourtListener.
Supreme Court rules Louisiana cannot use state immunity law to block federal civil rights claims
Impact3/10
What it does
The Court struck down Louisiana's application of its public health emergency immunity statute to federal claims, holding that states cannot use their own laws to shield defendants from liability under federal law. The case is sent back to Louisiana courts to evaluate the federal claims on their own merits under federal law. The ruling does not decide whether the plaintiff will ultimately win — only that the state immunity law cannot be the reason the federal claims are dismissed.
Who benefits
People who have filed or wish to file federal civil claims against healthcare providers in Louisiana for conduct during a public health emergency, whose cases were previously dismissed under the state immunity law.
Who is affected
Healthcare providers in Louisiana who had been shielded from federal civil lawsuits by the state's public health emergency immunity statute and who may now face those federal claims in court.
Practical impact
Louisiana courts must now reconsider the plaintiff's federal claims without using the state's public health emergency immunity law as a basis for dismissal. Healthcare providers in Louisiana who relied on that state immunity statute to defeat federal lawsuits may no longer do so, though they may still raise other defenses available under federal law. The ruling reinforces a well-established constitutional rule that applies in all states: state immunity laws cannot extinguish rights granted by Congress.
Majority reasoning
The Court held that while Louisiana is free to decide the scope of liability under its own state law, it has no power to extend that immunity to federal causes of action. The Supremacy Clause of the U.S. Constitution — which says federal law is the supreme law of the land and binds every state judge — means a state cannot pass a law that blocks claims created by federal law. The Court cited several prior rulings establishing this principle, including Howlett v. Rose (1990) and Haywood v. Drown (2009). The Court noted that the plaintiff's federal claims might still fail for other reasons under federal law itself, but that question must be decided by Louisiana courts on remand, not resolved by applying the state immunity statute.
Constitutional question
Can a state law that grants healthcare providers immunity from civil liability during public health emergencies also block plaintiffs from pursuing claims under federal law?
Precedent changed
The Court extended and reaffirmed the principle from Howlett v. Rose (1990) and Haywood v. Drown (2009) that states cannot confer immunity from federal causes of action; no prior precedent was overruled.