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By Andrew Stanton
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Conservative U.S. Supreme Court Justices Samuel Alito, Brett Kavanaugh and Clarence Thomas joined liberal Justices Sonia Sotomayor and Ketanji Brown Jackson to deliver the majority opinion in T.M. v. University of Maryland Medical System Corporation.
Justices often rule on ideological lines, but Thursday's ruling highlights how procedural fights can scramble the Supreme Court’s usual philosophical map. In this case, questions about the boundary between state and federal judicial power proved more unifying than political philosophy, drawing justices from opposite ends of the spectrum into the same camp despite those divides being on display throughout the Court’s current term.
What the Supreme Court Decision Means for Future Cases
With the ruling, the court provided new guidance to lower courts on how to apply the Rooker‑Feldman doctrine. A majority of justices ruled that federal district courts cannot review or overturn state‑court judgments even while those judgments are still being appealed in the state system, leaving that authority solely to the U.S. Supreme Court.
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In practical terms, this means that if someone loses a case in a state court (even a preliminary or lower-level state order), they cannot simply run to a federal district court to sue on constitutional grounds while their state-level appeal is still pending.

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What Was the Case About?
The case was brought by a person identified only as T.M., who said she has a medical condition that can cause psychosis when she ingests gluten. In March 2023, she accidentally did so and was taken to the emergency room at Baltimore Washington Medical Center, according to court filings.
She was allegedly held involuntarily at the hospital for about three months despite objections from her and her father, according to court documents. At that time, the medical center obtained an order authorizing forcible injections of antipsychotic medication.
Her parents filed several state and federal lawsuits seeking her release and opposing forced injections. They reached a settlement agreement to facilitate her release, and a state judge presiding over a state habeas petition entered the agreement as a consent order on June 12, 2023. She was then released on several conditions, including that she dismiss with prejudice all pending cases against the facility.
However, 10 days later, she and her parents obtained new counsel and sued them in federal district court, seeking a declaration that the order violated her due process rights. At the same time, she appealed the consent order to the Appellate Court of Maryland.
The District Court dismissed her complaint, ruling it did not have jurisdiction because of the Rooker-Feldman doctrine, a narrow rule stating that federal district courts are not able to act as appellate courts reviewing state‑court judgments; only the Supreme Court is able to do so.
What Did the Court Rule?
Thursday's ruling makes it clear that the doctrine applies even when judgments are being appealed in state courts. A majority of Supreme Court justices rejected the plaintiff’s argument in an opinion written by Sotomayor.
“This case asks whether this rule bars suit when the state court judgment at issue is subject to further review in state appellate proceedings. A straightforward application of the logic and reasoning underlying Rooker-Feldman leads to one conclusion: It does,” she wrote.
Sotomayor wrote that the plaintiff’s theory “cannot be squared with this Court’s precedents, which plainly adopted a different, more functional view of original and appellate jurisdiction than what T. M. advances here.”
Those theories require “a reimagining, rather than an application, of the Court’s Rooker-Feldman precedents,” she wrote.
“Ultimately, adopting T. M. and the dissent’s rule would require the Court to abandon a central part of Rooker’s reasoning and reinterpret the doctrine to rest solely on a strict negative inference from §1257,” she wrote.
The University of Maryland Medical System wrote in a statement to Newsweek that the ruling “provides important clarity regarding the legal framework governing state court proceedings.
“We appreciate the Supreme Court's careful consideration of this matter and its decision today and are pleased that the Supreme Court justices agreed with our position, which affirms the legal principles and longstanding precedent in this case.”
Who Dissented?
Conservative Justice Amy Coney Barrett wrote a dissenting opinion and was joined by Chief Justice John Roberts, Neil Gorsuch and liberal Elena Kagan.
Barrett wrote that Rooker-Feldman “stands on shaky ground” and that the court has “consciously kept its footprint small.”
“Its rationale has gotten no firmer, so we should make the doctrine no larger,” she wrote. “Beyond the difficulties of finding a statutory basis for Rooker-Feldman, parts of the United States Code undercut it. The doctrine is in tension, to say the least, with statutes granting district courts jurisdiction in categorical terms.”
What to Know About the Rooker-Feldman Doctrine
The Rooker‑Feldman doctrine traces back to the 1923 Supreme Court cases Rooker v. Fidelity Trust Co. and the 1983 case District of Columbia Court of Appeals v. Feldman (1983). In those cases, the Court held that federal district courts cannot function as appellate courts for state‑court judgments.
Some in the legal realm said courts should abandon the doctrine.
Sixth Circuit Court of Appeals Judge Jeffrey Sutton wrote in a 2020 ruling in the case VanderKodde v. Mary Jane M. Elliott that the rule has “caused so much mischief, creating needless complications, distracting litigants and courts from the properly presented federal issues at hand, and helping no one, not even the supposed beneficiaries of its largesse: state court judgments.”
T.M. v. University of Maryland Medical System Corporation: Read the Full Ruling
Here is a look at the full ruling issued on Thursday:
TMvUMD.pdf.PDF
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