SCOTUS Rules State Can’t Immunize Parties from Federal Civil Liability

In John Doe v. Dynamic Physical Therapy, LLC, 607 U.S. ____ (2025) the U.S. Supreme Court held that a State has no power to confer immunity from federal causes of action. The per curium decision reinforces the supremacy of federal law over state laws that attempt to shield parties from federal obligations.

Facts of the Case

The case involves claims for emotional distress damages based on the alleged refusal of Dynamic Physical Therapy, LLC (Dynamic) and one of its physical therapists, Scott Newton, PT, (Newton) (collectively, the “Respondent Health Care Providers”), to provide the Petitioner Patient John Doe with aquatic physical therapy or aquatherapy.

Doe alleged that he suffers from “ongoing chronic pain” and that on December 30, 2020, he met with Mr. Newton for a consultation and tour of Dynamic. During that consultation, Petitioner admits Mr. Newton “worked on [his] back” to gauge his pain. At the conclusion of the tour, Petitioner filled out paperwork and made two follow-up appointments for aquatherapy Doe alleged that before his appointment, he received a phone call from Mr. Newton advising that his HIV status was a contraindication for aquatherapy, but that Petitioner was still “more than welcome to come in for regular physical therapy.” 

Petitioner later filed a Verified Petition for Damages against the Respondent Health Care providers in a Louisiana trial court, asserting claims for emotional distress damages under the Louisiana Civil Rights Act for Persons with Disabilities, the Americans with Disabilities Act of 1990 (ADA), and the Rehabilitation Act of 1973 (RA).

The ADA and § 504 of the RA require public accommodations that receive federal funding to provide reasonable accommodations for people with disabilities and prohibits discrimination based on a disability.

The Respondent Health Care Providers sought dismissal by filing a Peremptory Exception of No Cause of Action, asserting that civil liability for damages was limited by the state’s public health emergency statute, the Louisiana Health Emergency Powers Act (LHEPA).

In the decision below, the Louisiana First Circuit Court of Appeals held that, for any claims made during the COVID-19 emergency, the federal statutes are violated only if healthcare providers acted with “gross negligence or willful misconduct,” a standard based on the LHEPA. Based on the foregoing, the Louisiana Court of Appeal ruled the state immunity statute barred Doe’s federal claims.

Supreme Court’s Decision

The Supreme Court reversed thejudgment of the Louisiana Court of Appeal. “Below, the Louisiana Court of Appeal held that this state statute barred plaintiff’s federal claims,” the justice wrote in a per curium opinion. “That decision is incorrect.” The Court went on to explain:

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 (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.”

The Supreme Court acknowledged that the Plaintiff’s federal claims may well fail on other federal grounds, but that is a matter for Louisiana courts to decide.