T. M. v. University of Maryland Medical System Corp.

Questions presented

SCOTUS records, cert granted 5 Dec 2025

Whether the Rooker-Feldman doctrine can be triggered by a state-court decision that remains subject to further review in state court.

Opinion summary

Etalia.ai summary of the majority opinion

The Court held that the Rooker-Feldman doctrine bars a federal district court from hearing a suit by a state-court loser who complains of injuries caused by a state-court judgment and asks the district court to review and reject it, even if that state judgment is still being reviewed in state appellate proceedings. Justice Sotomayor wrote the opinion. The Court said T. M. was directly attacking a consent order entered by a state court, claiming it violated due process and was obtained under duress, and seeking to have it declared void and unenforceable. The Court reasoned that Rooker and Feldman rest on the idea that district courts cannot exercise appellate jurisdiction over state-court judgments, while review of such judgments belongs only in this Court under 28 U. S. C. § 1257. It rejected the argument that Rooker-Feldman applies only to final judgments from a state’s highest court, saying that rule would conflict with precedent, create odd results, and undermine comity and federalism.

Dissent summary

Etalia.ai summary of the dissenting opinions

Justice Barrett dissented, joined by The Chief Justice, Justice Kagan, and Justice Gorsuch. The dissent argued that Rooker-Feldman should stay confined to the procedural settings of Rooker and Feldman, where the federal actions came after the state proceedings had ended. It said the Court has usually treated the doctrine as a narrow, often confusing exception and that the majority improperly expands it to cover pending state cases. The dissent also argued that a collateral attack in district court is not functionally the same as an appeal, pointing to differences in the record, evidence, preclusion, and remedies. It said § 1331 and § 1257 do not justify stripping district courts of jurisdiction over collateral attacks on state judgments while state review is still ongoing.