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 rendered before the district court proceedings commenced, regardless of whether those judgments remain subject to further review in state appellate proceedings.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT · Argued April 20, 2026
Parties — Petitioner: T. M. · Respondent: UNIVERSITY OF MARYLAND MEDICAL SYSTEM CORPORATION et al.
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.
Who prevailed — The respondents prevailed because the Court affirmed the dismissal of the petitioner's complaint for lack of subject matter jurisdiction.
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? The Court must determine if the doctrine is limited only to final judgments rendered by the highest court of a State.

Petitioner's argument
  • The Rooker-Feldman doctrine should apply only to "final judgments" rendered by the highest court of a State in which a decision could be had, as defined in 28 U. S. C. § 1257(a).
  • A federal action seeking the adjudication of a freestanding federal-question cause of action invokes the district court's original jurisdiction under 28 U. S. C. § 1331 and is akin to a collateral attack rather than an appeal.
  • The doctrine has caused confusion in lower courts and is often overused as a "docket-clearing mechanism."
  • Existing abstention and preclusion doctrines are sufficient to prevent premature federal interference in state proceedings.
Respondent's argument
  • The Rooker-Feldman doctrine bars jurisdiction when a party seeks "review and rejection" of a state-court judgment regardless of whether that judgment is final or subject to further state appeal.
  • Petitioner's suit falls within the narrow ground of the doctrine because she seeks to have a state consent order declared "unconstitutional, unenforceable, and void ab initio."
  • Allowing federal district courts to review judgments while they are on appeal in state court would undermine principles of federalism.
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 judgments rendered before the federal suit began, regardless of whether those judgments are subject to further state appellate review.
  • The Court reasoned that federal district courts possess "strictly original" jurisdiction under 28 U. S. C. § 1331 and lack the power to "review directly cases from state courts," as established in Atlantic Coast Line R. Co. v. Locomotive Engineers.
  • Under Rooker v. Fidelity Trust Co., seeking to "reverse or modify" a state-court judgment is an exercise of appellate jurisdiction, which is reserved exclusively for the Supreme Court under 28 U. S. C. § 1257(a).
  • The Court adopted a functional view of jurisdiction, noting that District of Columbia Court of Appeals v. Feldman explicitly rejected the idea that district courts can review state decisions simply because they are not yet within the Supreme Court's § 1257 jurisdiction.
  • Applying this to the facts, the Court found T. M. sought "review and rejection" of a consent order by asking the court to declare it "void ab initio," which is the paradigm situation for Rooker-Feldman under Exxon Mobil Corp. v. Saudi Basic Industries Corp.
  • The Court further reasoned that allowing such suits would undermine "cooperation and comity" between legal systems, citing Ruhrgas AG v. Marathon Oil Co.
  • It noted that adopting a "finality" requirement would create anomalous results by encouraging parties to file in federal court prematurely while state appeals are pending.
  • The Court concluded that abstention doctrines (such as those in Younger v. Harris and Colorado River Water Conservation Dist. v. United States) are insufficient because they may not apply when a plaintiff complains of injuries stemming directly from the judgment itself.
Separate opinions
Thomas, concurring
  • Argues that Rooker is correct as an original matter because "revising" another court's judgment is appellate jurisdiction by definition, citing Marbury v. Madison and Ex parte Bollman.
  • Contends that district courts lack revising power over state judgments because Congress has never granted them such authority in 28 U. S. C. § 1331 or other statutes.
Barrett, dissenting (joined by Roberts, Kagan, Gorsuch)
  • Argues that Exxon Mobil Corp. confines the doctrine to cases where state proceedings have "ended," meaning it should not apply while a state appeal is pending.
  • Contends that a collateral attack is not functionally equivalent to an appeal and that 28 U. S. C. § 1738 (Full Faith and Credit Act) is the proper mechanism for treating state judgments.
  • Asserts that dismissing a suit brought under 42 U. S. C. § 1983 on federalism grounds contradicts the statute's purpose of protecting people from unconstitutional state action, citing Mitchum v. Foster.