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Doe v. Dynamic Physical Therapy, LLC

607 U.S. 11 · 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.

Edition: preliminary print (page proof)
Source: https://www.supremecourt.gov/opinions/25pdf/607us1r03_1o23.pdf
Voices: 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,…
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.
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