In December 2025, the Supreme Court of the United States reversed a Louisiana appellate decision that had dismissed a patient’s federal discrimination claims based on a state public-health immunity statute.
The case, John Doe v. Dynamic Physical Therapy, LLC, et al., arose from events in December 2020, during the COVID-19 public health emergency. According to court records, the plaintiff—identified as “John Doe” to protect his privacy—sought aquatic physical therapy services from Dynamic Physical Therapy in Louisiana. After initially scheduling follow-up appointments, Doe alleged he was later informed that the clinic would no longer provide aquatic therapy because he is HIV-positive.
Doe filed suit in Louisiana state court, asserting claims under federal law, including the Americans with Disabilities Actand Rehabilitation Act of 1973, as well as claims under Louisiana law. He alleged discrimination based on disability and resulting emotional distress.
The defendants moved to dismiss the case, arguing that Louisiana’s Health Emergency Powers Act—specifically La. Rev. Stat. §29:771(B)(2)(c)(i)—provided healthcare providers immunity from civil liability for actions taken during a declared public health emergency. The trial court dismissed the case, and the Louisiana First Circuit Court of Appeal affirmed, holding that the statute barred Doe’s claims. The Louisiana Supreme Court declined review.
The U.S. Supreme Court unanimously reversed in a per curiam opinion. The Court held that while states may define immunity for state-law claims, they have no authority to confer immunity from federal causes of action. Citing the Supremacy Clause of the U.S. Constitution, the Court ruled that state courts must adjudicate federal claims under federal law, regardless of conflicting state statutes.
The case was remanded to Louisiana courts for further proceedings. The Supreme Court did not rule on the merits of Doe’s federal claims, noting that they may succeed or fail on other federal grounds.