Doe v. Dynamic Physical Therapy, LLC

607 U. S. ____ (2025) · 12/08/25

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.

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…