T. M. v. University of Maryland Medical System Corporation et al.
No. 25-197 · Decided June 18, 2026 · affirmed
Does the Rooker-Feldman doctrine bar 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? The Rooker-Feldman doctrine bars federal district court jurisdiction over cases brought by state-court losers seeking review and rejection of state-court judgments, regardless of whether the state-court judgment remains subject to further review in state appellate proceedings.
Vote & lineup5–4 on the judgment. Sotomayor delivered the opinion of the Court, joined by Thomas, Alito, Kavanaugh, Jackson (5). Dissent(s): Barrett (joined by Roberts, Kagan, Gorsuch). Concurrence(s): Thomas.
The question
Does the Rooker-Feldman doctrine bar 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? Specifically, does this bar apply even if the state-court judgment remains subject to further review in state appellate proceedings? Or does the doctrine apply only to final judgments rendered by the highest court of a State in which a decision could be had?
Petitioner's argument
- Rooker-Feldman should apply only to "[f]inal judgments or decrees rendered by the highest court of a State in which a decision could be had," as defined in 28 U. S. C. §1257(a).
- The suit constitutes a freestanding federal-question cause of action that invokes the district court's original jurisdiction under 28 U. S. C. §1331, rather than an attempt at appellate review.
- The Rooker-Feldman doctrine has caused confusion in lower courts and is frequently overused as a "docket-clearing mechanism."
- Existing abstention and preclusion doctrines are sufficient to prevent premature federal interference in state proceedings, rendering a broad application of Rooker-Feldman unnecessary.
Respondent's argument
- The petitioner's request for the District Court to declare a state-court consent order "unconstitutional, unenforceable, and void ab initio" is a paradigm example of seeking "review and rejection" of a state judgment.
- The Rooker-Feldman doctrine does not require that the state-court judgment be a final judgment from the highest court of the State.
- The case is too similar to the facts of *Rooker v. Fidelity Trust Co.* to justify a different jurisdictional outcome.
- Not stated.
The decision
- The Court held that the Rooker-Feldman doctrine bars federal district court jurisdiction over cases brought by state-court losers seeking review and rejection of state-court judgments, regardless of whether the judgment remains subject to further review in state appellate proceedings.
- The Court reasoned that federal district courts generally lack "any power to review directly cases from state courts," citing *Atlantic Coast Line R. Co. v. Locomotive Engineers*.
- Under 28 U. S. C. §1257(a), the power to review state-court judgments is lodged exclusively in the Supreme Court, meaning any attempt by a district court to "reverse or modify" such a judgment is an impermissible exercise of appellate jurisdiction.
- Relying on *Rooker v. Fidelity Trust Co.*, the Court noted that district court jurisdiction is "strictly original," and seeking to declare a state judgment "null and void" exceeds that authority.
- The Court invoked *District of Columbia Court of Appeals v. Feldman* to explicitly reject the notion that district courts have jurisdiction to review state judgments simply because those judgments are not yet within the Supreme Court's §1257 jurisdiction.
- The Court applied a functional view of jurisdiction, stating that Rooker-Feldman bars suits that "see[k] what in substance would be appellate review of [a] state judgment," as seen in *Johnson v. De Grandy*.
- The Court reasoned that allowing federal review while state appeals are pending would undermine the "[c]ooperation and comity" described in *Ruhrgas AG v. Marathon Oil Co.*
- The Court found that adopting the petitioner's rule would create anomalous results by encouraging parties to file in federal court prematurely to avoid the Rooker-Feldman bar.
- The Court concluded that abstention and preclusion doctrines are insufficient because they may not apply when a plaintiff complains of injuries stemming directly from the state-court judgment itself.
Separate opinions
Thomas, concurring
- Argues that *Rooker v. Fidelity Trust Co.* is correct as an original matter, asserting that the power to revise another court's judgment is inherently appellate.
- Relies on *Marbury v. Madison* and *Ex parte Bollman* to establish that "revising and correcting the proceedings in a cause already instituted" is the essential criterion of appellate jurisdiction.
- Asserts that since the founding, inferior federal courts have lacked general revising power over state-court judgments unless explicitly granted by statute.
Barrett, dissenting (joined by Roberts, Kagan, Gorsuch)
- Argues that *Exxon Mobil Corp. v. Saudi Basic Industries Corp.* confined the doctrine to cases where the federal action was brought "after the state proceedings ended."
- Contends that a "collateral attack" in district court is not functionally equivalent to an appeal because it allows new evidence and is subject to preclusion.
- Argues that the majority's decision ignores the Full Faith and Credit Act (28 U. S. C. §1738) and the purpose of 42 U. S. C. §1983, which is to protect federal rights from unconstitutional state action.