Background
The Louisiana Court of Appeal held that a Louisiana statute immunizing healthcare providers from civil liability during public health emergencies barred the plaintiff’s federal claims. The statute in question is La. Rev. Stat. Ann. Section twenty-nine seventy-seven-one, subsection B, paragraph two, subparagraph C, item one.
The court’s reasoning
The Court held that while defining the scope of liability under state law is the State’s prerogative, a State has no power to confer immunity from federal causes of action. The Court cited the Supremacy Clause, noting that state judges are bound to follow federal law notwithstanding any contrary state constitution or laws. The Court referenced Howlett versus Rose, Haywood versus Drown, and Williams versus Reed to support this principle.
A State has no power to confer immunity from federal causes of action.
Doe v. Dynamic Physical Therapy, LLC, 607 U. S. 11 (2025)
What it means going forward
State courts must allow federal claims to proceed even if state statutes attempt to grant immunity to defendants, such as healthcare providers, during public health emergencies.