Facts of the Case
In March 2023, T.M., a woman with a rare medical condition that triggers psychosis upon consuming gluten, was involuntarily committed to Baltimore Washington Medical Center after an episode. Her treating psychiatrist sought and received state approval to forcibly administer antipsychotic medication; T.M. contested this but was unsuccessful in administrative proceedings. Independent psychiatrists later stated that T.M. no longer required inpatient care. To secure her release, T.M. and the hospital negotiated an oral agreement, which was formalized as a state court consent order. The order allowed her to leave the hospital on the condition that she comply with ongoing psychiatric treatment and medications, switch providers, and drop pending lawsuits. Her parents, J.M. and A.M., were also bound to notify authorities if she failed to comply.
Ten days later, represented by new counsel, T.M. and her parents filed the present federal lawsuit claiming that the consent order was unconstitutional and entered under duress. They challenged the order as violating T.M.’s due process rights and sought declaratory and injunctive relief invalidating its enforcement. They did not request damages or challenge the initial commitment decisions.
The U.S. District Court for the District of Maryland dismissed the lawsuit. It held that T.M.’s claims were barred by the Rooker-Feldman doctrine, which prevents parties who lose in state courts from challenging injuries caused by state-court judgments, because they amounted to a request for federal review of a state court judgment. It also dismissed the parents’ claims for failure to state a constitutional violation. The U.S. Court of Appeals for the Fourth Circuit affirmed, concluding that T.M. was a “state-court loser” seeking to undo a state judgment still reviewable in Maryland courts. Nonetheless, it remanded for the district court to modify T.M.’s dismissal to be without prejudice, due to lack of jurisdiction.
Questions
Can the Rooker-Feldman doctrine, which prevents parties who lose in state courts from challenging injuries caused by state-court judgments, be triggered by a state-court decision that remains subject to further review in state court?
Conclusions
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The Rooker-Feldman doctrine, which bars federal district courts from reviewing and nullifying state-court judgments, applies even when the state-court judgment under attack remains subject to an ongoing appeal in state court. Justice Sonia Sotomayor authored the 5-4 majority opinion of the Court.
The Rooker-Feldman doctrine rests on a foundational divide between two types of judicial power: "original jurisdiction" (a court's power to hear a case for the first time) and "appellate jurisdiction" (a court's power to review and correct another court's judgment). Congress granted federal district courts only original jurisdiction over federal-question cases under 28 U.S.C. § 1331. When a state-court loser asks a federal district court to declare that state-court judgment void or unconstitutional, the plaintiff is not really filing a fresh lawsuit — they are asking the district court to act as an appeals court over the state judiciary. District courts cannot do this. Congress reserved that appellate power exclusively for the Supreme Court under 28 U.S.C. § 1257, which grants the Supreme Court jurisdiction over final judgments from the highest state court in which a decision could be had.
Limiting Rooker-Feldman to cases where the state's highest court has already issued a final judgment contradicts prior precedent and produces harmful results. Earlier cases treated the doctrine as turning on what a plaintiff functionally demands — reversal of a state-court judgment — not on which rung of the state appellate ladder that judgment has reached. The Feldman decision explicitly rejected the idea that district courts gain jurisdiction to review state-court judgments simply because the Supreme Court has not yet acquired jurisdiction over them. Allowing such a workaround would also damage comity — the mutual respect and cooperation between state and federal court systems — by letting federal courts insert themselves into live state appeals. It would also create arbitrary, timing-based loopholes that encourage parties to race to federal court before a state appeal concludes, duplicating litigation even when the state process might resolve the dispute entirely.
Justice Clarence Thomas concurred, arguing that Rooker is correct as an original constitutional matter because asking any court to revise another court's judgment has always been the defining feature of appellate jurisdiction, and Congress has never granted federal district courts that power over state-court judgments.
Justice Amy Coney Barrett dissented (joined by Chief Justice John Roberts and Justices Elena Kagan and Neil Gorsuch), arguing that Exxon Mobil Corp. v. Saudi Basic Industries Corp. (2005) already confined Rooker-Feldman to cases where state proceedings had fully ended, that seven circuits correctly applied that limit, and that the majority expands the doctrine by resurrecting a §1331 rationale that Exxon had discarded.
