Episode Details

T.M. v. University of Maryland Medical System Corporation | Case No. 25-197 | Docket Link: Here | Argued: April 20, 2026 | Decided: June 18, 2026

Overview: A Maryland woman signed a state-court consent order to secure release from involuntary psychiatric commitment, then challenged that order in federal district court while her state-court appeal remained pending — pushing the limits of the Rooker-Feldman doctrine.

Question Presented: Whether the Rooker-Feldman doctrine bars federal district court jurisdiction over suits challenging state-court judgments that remain subject to further review in state appellate proceedings.

Posture: Fourth Circuit affirmed District Court's dismissal of T.M.'s complaint under Rooker-Feldman for lack of jurisdiction.

Main Arguments:

T.M. (Petitioner):

• (1) Rooker-Feldman applies only after state proceedings end, per Exxon Mobil's confinement to the procedural circumstances of Rooker and Feldman;
• (2) Section 1257 cannot support a negative inference extending the doctrine to non-final state-court judgments;
• (3) preclusion and abstention doctrines adequately address federalism concerns without imposing a blunt jurisdictional bar.

UMD Medical System (Respondent):

• (1) Exxon Mobil's four-element test contains no finality requirement; district courts lack appellate jurisdiction to void state-court judgments regardless of pending state review;
• (2) T.M. satisfies every Rooker-Feldman element — she asked a federal court to declare void a consent order entered ten days before she filed;
• (3) T.M.'s rule spawns parallel duplicative litigation, gamesmanship, and federalism harm that abstention and preclusion fail to prevent.

Holding: The Rooker-Feldman doctrine bars federal district court jurisdiction over suits brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and seeking federal review and rejection of those judgments, regardless of whether the state-court judgment remains subject to further review in state appellate proceedings. Affirmed.

Voting Breakdown: 5-4. Justice Sotomayor delivered the opinion of the Court, joined by Justices Thomas, Alito, Kavanaugh, and Jackson. Justice Thomas filed a concurring opinion. Justice Barrett filed a dissenting opinion, joined by Chief Justice Roberts and Justices Kagan and Gorsuch. Fourth Circuit affirmed.

Opinion: Here

Majority Reasoning:

• (1) T.M.'s finality theory contradicts precedent — Rooker (1923), Feldman (1983), and Exxon Mobil (2005) all rest on a functional distinction between original and appellate jurisdiction, not on section 1257's finality requirement;
• (2) T.M.'s rule produces arbitrary results and invites gamesmanship — identical plaintiffs with different filing timing reach opposite outcomes;
• (3) abstention and preclusion doctrines don't substitute where a plaintiff directly attacks a state-court judgment as the source of injury.

Separate Opinions:

• Justice Thomas concurred in full, writing separately to ground Rooker in constitutional text and Founding history — the power to revise another court's judgment always constituted appellate jurisdiction, and Congress never granted district courts that revising power over state civil judgments.
• Justice Barrett dissented, joined by Chief Justice Roberts and Justices Kagan an