T. M. v. University of Md. Medical System Corporation Revisions: 6/19/26
The Court ruled that federal district courts cannot be used to second-guess a state court's judgment even if that judgment is still being appealed within the state court system, extending a doctrine that normally blocks federal district courts from acting like an appeals court over state rulings.
The decision resolves a split among federal appeals courts over exactly when this jurisdictional bar kicks in, and it means people unhappy with a state court's ruling must pursue further review in the state appellate courts (and ultimately the U.S. Supreme Court), not in a federal trial court, regardless of whether the state case is truly final.
“A straightforward application of the logic and reasoning underlying Rooker-Feldman leads to one conclusion: It does.”
The Court's opening statement that the doctrine bars suit even when state appeals remain pending.
How it got here: A federal trial court dismissed T. M.'s suit against the consent order under the Rooker-Feldman doctrine; the Fourth Circuit affirmed, and T. M. asked the Supreme Court to resolve a circuit split.
The Case in Depth
What happened
T. M. has a medical condition that can cause psychosis when she eats gluten. After an accidental exposure in 2023, she was involuntarily committed and, over her objections, forcibly medicated. A flurry of state and federal lawsuits followed, ending in a settlement that a state judge entered as a consent order requiring her release on several conditions, including dismissing her other claims against the hospital and its staff.
The question before the Court
If someone loses in a state trial court and appeals within the state system, can they also ask a federal district court to throw out that state ruling while the state appeal is still pending?
The Court's answer
No — the Court ruled that the Rooker-Feldman doctrine, which blocks federal trial courts from acting like an appeals court over state-court rulings, applies even when the state judgment is still being appealed within the state system. T. M.'s federal lawsuit asked a federal district court to declare her state consent order unconstitutional and block it, which is exactly the kind of review of a state judgment only the Supreme Court, not federal trial courts, may perform.
The Court rejected the argument that this bar should apply only once a judgment becomes truly final under the statute governing Supreme Court review of state courts. It found that limiting the bar that way would create inconsistent results depending purely on timing, undermine cooperation between state and federal courts, and was not supported by its past decisions in this area, so the federal suit was correctly dismissed.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
People who lose in state court and want a federal do-over will now find that door closed even if their state appeal is still pending, forcing them to litigate to the end of the state appellate process first. This affects anyone contemplating parallel state and federal lawsuits, and it clarifies for lower federal courts, which had split on the question, when they must dismiss such suits for lack of jurisdiction.
What changes now
This is a final merits decision resolving a circuit split, not a temporary order. T. M.'s federal suit remains dismissed, and her state-court appeal of the consent order — currently stayed — can proceed in Maryland's appellate courts. Other circuits that previously required state proceedings to have 'ended' before applying Rooker-Feldman will now need to follow this broader rule.
What this does not decide
The Court said it was neither expanding nor narrowing the Rooker-Feldman doctrine, just applying it as previously understood. It did not decide whether Rooker or Feldman were correctly decided in the first place, an argument it said was not properly before it.
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 agreed in full but wrote to defend Rooker as correct on its own terms, tracing the historical meaning of 'appellate jurisdiction' back to the founding era, Marbury v. Madison, and Ex parte Bollman. He argued that reviewing another court's judgment for legal errors is inherently an exercise of appellate power that Congress has only ever given to the Supreme Court over state courts, not to federal district courts.
Dissent — Justice Barrett
“Because Rooker-Feldman stands on shaky ground, we have consciously kept its footprint small.”The dissent's core objection that the majority is expanding a doctrine meant to stay narrow.
Justice Barrett argued that the Court's 2005 Exxon decision had deliberately confined Rooker-Feldman to cases, like Rooker and Feldman themselves, filed only after state proceedings had fully ended, and that seven circuits had followed that limit. She would have held that because T. M.'s state appeal was still pending, the doctrine did not apply and the federal suit could proceed, and she criticized the majority for reviving a discarded rationale and inventing policy justifications not found in the Court's precedents. 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 really just asking the federal court to review and undo that state court's ruling, because only the Supreme Court has that kind of appellate power over state judgments.
- The Court found that T. M.'s federal suit fit squarely within this doctrine: she was asking the federal district court to declare the state consent order unconstitutional and void and to block its enforcement, which is exactly the kind of 'review and rejection' of a state ruling the doctrine forbids.
- The Court rejected T. M.'s argument that the doctrine should apply only when the state judgment is a final ruling from a state's highest court under 28 U.S.C. § 1257, the statute giving the Supreme Court appellate power over state courts. It found that its past cases, including the founding case Rooker (which first announced this bar) and the D.C. case Feldman, never turned on whether the state judgment had reached that final stage.
- The Court reasoned that letting federal district courts review state judgments still on appeal within the state system, but not those that are final, would produce inconsistent results based purely on timing and would undercut cooperation between state and federal courts.
- The Court also concluded that other tools federal courts have — like abstention doctrines that avoid interfering with ongoing state cases, and preclusion rules that stop relitigating settled issues — do not reliably cover cases like this one, where the injury comes directly from the state judgment itself.
- Because T. M.'s case fell within these established limits regardless of whether her state appeal was still pending, the Court concluded the bar on federal district court jurisdiction applied to her suit.
Doctrinal impact
Cases affected by this decision
Reaffirms Rooker v. Fidelity Trust Co. (263 U. S. 413)
The Court relies on Rooker's reasoning that district courts have only original, not appellate, jurisdiction over state judgments.
Reaffirms District of Columbia Court of Appeals v. Feldman (460 U. S. 462)
The Court treats Feldman as confirming district courts cannot review state-court judgments even before Supreme Court jurisdiction attaches.
Limits Exxon Mobil Corp. v. Saudi Basic Industries Corp. (544 U. S. 280)
The Court reads Exxon's 'confined' language as not requiring state proceedings to have fully ended, narrowing the dissent's reading.