T. M. v. University of Md. Medical System Corporation
The Court ruled that federal district courts cannot hear a lawsuit asking them to undo a state court's ruling, even if that ruling is still being appealed inside the state court system.
The decision keeps a narrow but firm rule in place: people who lose in state court must pursue further review through the state's own appellate courts (and ultimately the Supreme Court), not by suing in a federal trial court instead.
“T. M. is complaining of injuries caused by, and is 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 majority explains why T. M.'s lawsuit falls within the Rooker-Feldman doctrine.
How it got here: A federal trial court dismissed T. M.'s suit for lack of jurisdiction under the Rooker-Feldman doctrine; the Fourth Circuit affirmed, and T. M. asked the Supreme Court to review that ruling.
The Case in Depth
What happened
T. M. has a medical condition that can cause psychosis if she eats gluten. After an accidental exposure in 2023, she was involuntarily hospitalized for months, and doctors got court permission to force antipsychotic medication on her. She and the hospital later settled, and a state judge entered the deal as a consent order requiring her release in exchange for conditions like dropping her other lawsuits.
The question before the Court
If a state court's ruling is still being appealed within the state court system, can the person who lost still ask a federal trial court to throw it out?
The Court's answer
No — the Court ruled that the Rooker-Feldman doctrine blocks a federal district court from hearing T. M.'s suit even though her state-court consent order was still being appealed in Maryland's courts. The doctrine bars federal trial courts from acting like an appeals court over state-court judgments, and that concern applies whether or not the state judgment has finished working through every level of state review.
The Court explained that what matters is whether a plaintiff is functionally asking a federal trial court to review and reject a state court's ruling — here, T. M. asked the court to declare her consent order void and block its enforcement, which is exactly that kind of request. Letting timing determine the outcome, the Court said, would create arbitrary results and invite people to rush to federal court early, so the doctrine applies regardless of whether state appeals are still pending.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
People and businesses that lose a state-court case cannot shortcut the appeals process by filing a fresh lawsuit in federal district court while their state appeal is pending. This closes off a strategy some litigants used to get a second, earlier shot at undoing an unfavorable ruling, and it channels disputes back through the state appellate system.
What changes now
The Fourth Circuit's dismissal of T. M.'s federal lawsuit stands, meaning she cannot pursue her federal challenge to the consent order in district court. Her state-court appeal of the same consent order, which had been stayed, remains available to her in Maryland's appellate courts. This is a final merits decision resolving a circuit split over how the Rooker-Feldman doctrine applies to non-final state judgments.
What this does not decide
The Court did not decide whether Rooker and Feldman were correctly decided in the first place, an issue the dissent raised but the majority said was outside the question presented. The ruling also does not address when abstention or preclusion doctrines might separately limit federal suits challenging state proceedings.
Concurrences and dissents
How the Justices voted
Majority (5). Justice Sotomayor (author), joined by Justice Thomas, Justice Alito, Justice Kavanaugh, and Justice Jackson.
Dissent (4). Justice Barrett (author), joined by Justice Roberts, Justice Kagan, and Justice Gorsuch.
Concurrence — Justice Thomas
Justice Thomas joined the majority in full but wrote separately to argue that Rooker was correctly decided on originalist grounds. He traces the historical meaning of 'appellate jurisdiction' from the Founding through Marbury v. Madison and Ex parte Bollman, concluding that only the Supreme Court has ever had power to revise state-court judgments in federal-question cases, and that Congress never gave district courts that power.
Dissent — Justice Barrett
Justice Barrett argued that Exxon Mobil deliberately confined Rooker-Feldman to cases filed after state proceedings had fully ended, and that most circuits had correctly read Exxon that way. She contended the majority wrongly revives an abandoned statutory rationale, invents unpersuasive policy justifications about anomalous outcomes and federalism, and expands a doctrine that Exxon had intentionally narrowed, when preclusion and abstention doctrines already do most of the necessary work. Read the full dissent →
How the Court got there
The legal reasoning, step by step
- The Court applied the Rooker-Feldman doctrine, which says federal trial courts cannot hear lawsuits from people who lost in state court and are now asking the federal court to review and throw out that state-court ruling, because only the Supreme Court has that kind of appellate power over state courts.
- The Court found T. M.'s suit fit squarely within this doctrine: she was complaining about injuries caused by the state court's consent order itself and asking the federal court to declare it unconstitutional and void — exactly the kind of 'review and rejection' the doctrine forbids.
- The Court rejected T. M.'s argument that the doctrine should apply only when the state judgment is a truly final ruling from a state's highest court. It reasoned that the key question has always been whether a suit functionally asks a federal trial court to act like an appeals court over a state ruling, not whether that state ruling has finished working its way through every level of state appeal.
- The Court also reasoned that letting federal trial courts review state rulings still on appeal would create odd, timing-based results — encouraging losing parties to rush to federal court early, before a state appeal concludes, just to get a case a state high court could later resolve anyway.
- Because letting district courts intervene mid-appeal would also strain the cooperative relationship between state and federal courts, the Court concluded that the doctrine bars review regardless of whether the state ruling is still being appealed in state court.
Doctrinal impact
Cases affected by this decision
Reaffirms Exxon Mobil Corp. v. Saudi Basic Industries Corp. (544 U. S. 280)
The Court relies on Exxon as confining Rooker-Feldman's narrow scope while rejecting the dissent's reading that it also requires final state-court judgments.
Reaffirms Rooker v. Fidelity Trust Co. (263 U. S. 413)
The Court treats Rooker's core reasoning about original versus appellate jurisdiction as still controlling and applicable here.
Reaffirms District of Columbia Court of Appeals v. Feldman (460 U. S. 462)
The Court relies on Feldman's rejection of the idea that district courts may review judgments not yet reviewable by the Supreme Court.