T. M. v. University of Maryland Medical System (25-197)
- Term
- OT 2025
- Argued
- 2026-04-20
- Decided
- 2026-06-18
- Vote
- 5-4 for Univ. of Maryland Medical System
- Opinion
- Justice Sotomayor
- Majority
- Sotomayor, Thomas, Alito, Kavanaugh, Jackson
- Dissent
- Barrett, Roberts, Kagan, Gorsuch
Holding
Affirmed the Fourth Circuit 5-4 for the RESPONDENT (UMMS). Sotomayor delivered the opinion of the Court, joined by Thomas, Alito, Kavanaugh, and Jackson; Thomas concurred; Barrett dissented, joined by Roberts, Kagan, and Gorsuch. Held: Rooker-Feldman bars federal district-court jurisdiction over suits by state-court losers complaining of injuries from state-court judgments rendered before the federal suit, REGARDLESS of whether the state judgment remains subject to further review in state appellate proceedings. T.M.'s narrowing rule (RF reaches only final judgments of a State's highest court that fall within this Court's 1257 jurisdiction) was rejected as inconsistent with the Court's precedents (Rooker, Feldman n.16, De Grandy: 1331 is read functionally, not via a strict 1257 negative inference) and as producing anomalous, federalism-eroding, forum-racing outcomes. The Court declined to reach T.M.'s Question II (overrule RF) and 'neither expands nor constrains' the doctrine.
Pre-decision prediction
T. M. 8-1 (92% confidence).
Opinion of the Court
Authored by Justice Sotomayor (15,262 words total).
SYSTEM CORPORATION ET AL. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 25–197.
Argued April 20, 2026—Decided June 18, 2026
The Rooker-Feldman doctrine bars federal district courts from exercising jurisdiction over cases brought by state-court losers seeking review and rejection of state-court judgments rendered before district court proceedings commenced. See Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U. S. 280, 284. This case asks whether the doctrine applies only to final judgments rendered by the highest court of a State in which a decision could be had, or whether it also bars suit when the state-court judgment at issue remains subject to further review in state appellate proceedings. Petitioner T. M. alleges that she has a medical condition that causes changes in her mental status, including psychosis, when she ingests gluten. In March 2023, T. M. accidentally ingested gluten and was taken to the emergency room at Baltimore Washington Medical Center, where, after an administrative hearing and over her and her father’s objections, she was involuntarily committed for about three months. During her stay, T. M.’s treating psychiatrist and the medical center obtained an order authorizing the facility to forcibly inject T. M. with antipsychotic medication. These events prompted a flurry of litigation, with T. M. and her parents filing several state and federal lawsuits seeking T. M.’s release and to avoid the forced injections. T. M. and respondents negotiated a settlement agreement to facilitate T. M.’s discharge, and the state judge presiding over T. M.’s state habeas petition entered the agreement as a consent order on June 12, 2023. The consent order provided for T. M.’s immediate release subject to several conditions, including that T. M. obtain a new treating psychiatrist, continue taking her prescribed medications, and dismiss
CORPORATION Syllabus with prejudice all pending actions against respondents. Ten days after the state court entered the consent order, T. M. and her parents obtained new counsel and sued respondents in Federal District Court for the District of Maryland, seeking a declaration that the consent order violated T. M.’s federal and state due-process rights, a declaration that the order was obtained under duress, and an injunction preventing its enforcement. Meanwhile, T. M. appealed the consent order to the Appellate Court of Maryland and raised similar arguments. T. M. later successfully moved to stay the state-court appeal to prevent inconsistent rulings. The District Court dismissed the complaint sua sponte for lack of subject matter jurisdiction under the Rooker-Feldman doctrine. The Fourth Circuit affirmed, rejecting T. M.’s argument that Rooker-Feldman applies only to judgments that are final judgments from the highest court of a State in which the decision could be had.
Held: The Rooker-Feldman doctrine bars federal district court jurisdiction over cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and seeking district court review and rejection of those judgments, regardless of whether the state-court judgment remains subject to further review in state appellate proceedings. Pp. 5– 18. (a) Federal district courts generally lack “any power to review directly cases from state courts.” Atlantic Coast Line R. Co. v. Locomotive Engineers, 398 U. S. 281, 286. The Supreme Court is the only federal court with appellate jurisdiction to review state-court judgments, and that jurisdiction extends only to “[f]inal judgments or decrees rendered by the highest court of a State in which a decision could be had,” 28 U. S. C. §1257(a). In Rooker v. Fidelity Trust Co., 263 U. S. 413, the Court held that a Federal District Court lacked jurisdiction to declare a state-court judgment “null and void” because doing so would be “an exercise of appellate jurisdiction,” which only the Supreme Court possesses, and the “jurisdiction possessed by the District Courts is strictly original.” Id., at 414–416. In District of Columbia Court of Appeals v. Feldman, 460 U. S. 462, the Court held that a Federal District Court lacked jurisdiction to “review” a final judicial determination of the D. C. high court because such “[r]eview . . . can be obtained only in [the Supreme] Court” under §1257. Id., at 476, 482. Rooker and Feldman rest on two closely related bases of reasoning. First, when plaintiffs “essentially invit[e] federal courts of first instance to review and reverse unfavorable state-court judgments,” they are seeking an exercise of appellate jurisdiction. Exxon, 544 U. S., at 283–284. Second, such “appellate jurisdiction to reverse or modify a state-court judgment is lodged, . . . by 28 U. S. C. §1257, exclusively in [the Supreme] Court.” 544 U. S., at 283. This Court has since refused
Syllabus to expand the Rooker-Feldman doctrine but has also reaffirmed its rule in the narrow ground it occupies. Exxon, 544 U. S., at 284. Pp. 5–8. (b) T. M.’s case falls within “the narrow ground occupied by RookerFeldman,” Exxon, 544 U. S., at 284, because she is complaining of injuries caused by, and seeking relief from, the state-court judgment itself, arguing that the consent order violates her federal and state due process rights and was entered into under duress. The consent order was rendered 10 days before T. M. commenced this federal lawsuit, and she plainly seeks “review and rejection” of the “ ‘Consent Order’ ” by asking the District Court to declare it “unconstitutional, unenforceable, and void ab initio” and to enjoin its “enforcement.” 139 F. 4th 344, 347. P. 8. (c) The Court rejects T. M.’s argument that Rooker-Feldman should apply only to final judgments rendered by the highest court of a State in which a decision could be had, i.e., the kinds of judgments that strictly fall within this Court’s jurisdiction under 28 U. S. C. §1257. Pp. 9–18. (1) T. M.’s theory cannot be squared with the Court’s precedents. T. M. reads the Court’s prior Rooker-Feldman cases not to evince any concern about district courts exercising what amounts to appellate jurisdiction over state-court judgments, but instead as relying on a strict negative inference from §1257: when this Court has jurisdiction over a state-court judgment, district courts must not. But this Court’s precedents plainly adopted a more functional view of what constitutes original and appellate jurisdiction under §1331. In Rooker, nothing in the Court’s reasoning suggested the outcome would have been different had the judgment still been on appeal; the Court held that seeking to “reverse or modify the [state-court] judgment” would be an “exercise of appellate jurisdiction,” which the District Court lacks because it has “strictly original” jurisdiction. 263 U. S., at 416. Later cases confirmed that Rooker-Feldman bars suits in federal district court that “see[k] what in substance would be appellate review of [a] state judgment,” regardless of whether the judgment formally falls within this Court’s §1257 jurisdiction. Johnson v. De Grandy, 512 U. S. 997, 1005–1006. In fact, Feldman explicitly rejected the notion that district courts have jurisdiction to review state-court judgments so long as the judgments are not yet within this Court’s §1257 jurisdiction. 460 U. S., at 483– 484, n. 16 (explaining that irrespective of the Court’s “jurisdiction to review a final state court judgment . . . ‘lower federal courts possess no power whatever to sit in direct review of state court decisions’ ”). Pp. 9–13. (2) If departure from this Court’s precedents alone were not enough to affirm the dismissal of T. M.’s suit under Rooker-Feldman, adopting T. M.’s rule would also create anomalous outcomes and
CORPORATION Syllabus undermine federalism principles. Allowing federal district courts to review state-court judgments while they are on appeal in the statecourt system would undermine the “[c]ooperation and comity” on which the Nation’s federal system is built. Ruhrgas AG v. Marathon Oil Co., 526 U. S. 574, 586. T. M.’s rule would also produce arbitrarily different results depending on when a federal suit seeking review of a state-court judgment is filed, encouraging parties to file earlier in federal court while the state appellate proceedings are pending, and to duplicate their efforts even though the state process may resolve the dispute in their favor. T. M.’s contention that abstention and preclusion doctrines can do nearly all of the work that Rooker-Feldman does is unavailing. It is unclear if such doctrines even apply in cases where a plaintiff complains of injuries that stem directly from a state-court judgment rather than attempting to relitigate the same claims. Federalism principles are thus best served by continuing to apply Rooker-Feldman to federal plaintiffs seeking review of state-court judgments, regardless of whether those judgments are final trial-court judgments or those of a State’s highest court. Pp. 13–16. (3) T. M. contends that the Court should adopt her position because it will generally cabin Rooker-Feldman, a doctrine she claims has caused confusion and is overused as a docket-clearing mechanism in the lower courts. T. M.’s proposed rule would fail to address the source of confusion in current Rooker-Feldman doctrine—determining when a plaintiff is seeking federal review and rejection of a state-court judgment—and would add a new source of confusion by requiring courts to determine whether a state-court judgment is a reviewable final judgment under §1257(a). In any event, the animating force behind T. M.’s arguments is the belief that Rooker and Feldman were wrongly decided, but this issue is not fairly included in the question presented. The Court today neither expands nor constrains RookerFeldman but leaves the doctrine as it found it. Pp. 16–18.
139 F. 4th 344, affirmed. SOTOMAYOR, J., delivered the opinion of the Court, in which THOMAS, ALITO, KAVANAUGH, and JACKSON, JJ., joined. THOMAS, J., filed a concurring opinion. BARRETT, J., filed a dissenting opinion, in which ROBERTS, C. J., and KAGAN and GORSUCH, JJ., joined.
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