T. M. v. University of Md. Medical System Corporation Revisions: 6/19/26
Decision
The Supreme Court held that the Rooker-Feldman doctrine prevents federal district courts from reviewing state-court judgments even if those judgments are still being appealed in state court.
The Court ruled that federal district courts cannot review or overturn state-court decisions, regardless of whether the state legal process is finished.
Plain-English summary generated by AI from the Court's published opinion on July 1, 2026. Always read the official opinion for the controlling text.
Key Takeaways
- 01Federal district courts generally lack the power to review or reject judgments made by state courts.
- 02The Rooker-Feldman doctrine applies even if the state-court judgment is still being appealed within the state system.
- 03Appellate review of state-court judgments is exclusively the role of the U.S. Supreme Court, not lower federal courts.
Inside the Court
5–4
Decision
- Opinion by
- Justice Sotomayor
- Majority
- SotomayorThomasAlitoKavanaughJackson
- Dissent
- BarrettRobertsKaganGorsuch
Why It Matters
This decision preserves the rule that only the Supreme Court can hear appeals from state courts, preventing federal district courts from acting as appellate courts.
Who Is Affected?
Civil litigants in state courts
They cannot seek federal district court intervention to overturn state-court orders while their state appeals are still pending.
Federal district court judges
They must dismiss lawsuits that essentially ask for the review and rejection of state-court judgments, even if the state litigation is ongoing.
What Happened?
A woman named T. M. was involuntarily committed to a medical facility following a gluten-related medical episode. After several lawsuits, she signed a settlement agreement that was entered as a state-court consent order. T. M. later sued in federal district court to have the order declared void while also appealing the order in state court. The federal district court dismissed her lawsuit, finding it lacked the power to review the state court's decision.
Legal Question
Does the Rooker-Feldman doctrine bar federal district courts from hearing cases that challenge state-court judgments even when those judgments are still being appealed in state court?
Why the Court Ruled This Way
In an opinion by Justice Sotomayor, the Court affirmed that the Rooker-Feldman doctrine applies regardless of whether a state-court judgment remains subject to further review in state appellate proceedings. The Court reasoned that federal district courts possess 'strictly original' jurisdiction under 28 U.S.C. §1331, whereas appellate review of state-court judgments is reserved exclusively for the Supreme Court under 28 U.S.C. §1257. The majority rejected the argument that this bar only applies to 'final' judgments from a state's highest court, noting that allowing district courts to review ongoing state cases would create 'anomalous outcomes' and undermine federalism. The Court held that when a plaintiff asks a federal district court to reject a state-court judgment issued before the federal suit began, the district court lacks jurisdiction.
Arguments in Favor
Supporters of this interpretation argue it prevents federal district courts from interfering with state judicial processes and maintains the clear boundary between state and federal court systems. They contend that allowing these lawsuits would encourage duplicative litigation and lead to inconsistent rulings.
Arguments Against
Critics argue that the Rooker-Feldman doctrine should be strictly limited to cases that actually fall within the Supreme Court's specific appellate authority over final state judgments. They suggest this interpretation may leave some litigants without a federal forum to address constitutional injuries caused by lower state-court orders.
Timeline
March 2023
T. M. was involuntarily committed
She was taken to the emergency room after ingesting gluten and committed following an administrative hearing.
June 12, 2023
State court entered a consent order
The order provided for T. M.'s release subject to conditions, including the dismissal of pending lawsuits.
June 2023
T. M. filed suit in federal district court
Ten days after the consent order, she sought to have the order declared unconstitutional and void.
June 18, 2026
Supreme Court issued its decision
The Court held that the federal district court lacked jurisdiction to review the state-court order.
What This Means for Everyday Americans
This ruling means that if a person loses in a state court, they generally cannot go to a local federal district court to have that decision overturned. Instead, they must follow the state's own appeal process to the very top. Only after the highest state court has finished with the case can the matter potentially be brought to a federal court, and specifically only to the U.S. Supreme Court. This ensures that federal district courts do not act as supervisors over state judges.
What Happens Next?
The case will be affirmed, meaning the federal district court's dismissal remains in place. T. M. may continue to pursue her claims through the Appellate Court of Maryland, where her state-level appeal was previously stayed.
Explain It Like I'm 12
The Supreme Court decided that if a state judge makes a ruling, a person cannot go to a lower federal court to ask that federal judge to cancel the state judge's order. This is true even if the person is still trying to appeal the case in the state's own higher courts. The Court said that federal and state courts are mostly separate. Lower federal courts are meant to start new cases, not fix mistakes from state courts. Only the U.S. Supreme Court has the power to look at a completed case from a state's highest court and change it.
Broader Context
The decision clarifies the scope of the Rooker-Feldman doctrine, a narrow legal rule that prevents federal district courts from sitting in direct review of state-court decisions. It reinforces the principle that state and federal courts are separate systems with the Supreme Court as the sole point of intersection for federal questions.
Key Players
T. M.
The petitioner who was involuntarily committed and later challenged a state-court consent order in federal court.
University of Maryland Medical System Corporation
The respondent and operator of the medical facility where T. M. was committed.
Justice Sotomayor
The justice who delivered the opinion of the Court.
Justice Barrett
The justice who filed a dissenting opinion.