On June 18, 2026, the Supreme Court of the United States decided T.M. v. University of Maryland Medical System Corporation et al., No. 25-197, holding that the Rooker-Feldman doctrine — which bars federal district courts from exercising jurisdiction over "cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments" — applies even when those judgments are subject to further review in state appellate proceedings.
Petitioner T.M. was involuntarily committed to a medical facility after accidentally ingesting gluten, which she alleges causes episodes of psychosis due to a medical condition. T.M. and her parents filed several state and federal lawsuits seeking to have T.M. released from involuntary commitment and to avoid forced injections. T.M. and respondents negotiated a settlement agreement, and the state court entered the agreement as a consent order providing for T.M.'s release subject to several conditions. Ten days after the state court entered the consent order, T.M. obtained new counsel and sued respondents in the US District Court for the District of Maryland, seeking "a declaration that the consent order violated T.M.'s federal and state due-process rights, a declaration that the order was obtained under duress, and an injunction preventing the order's enforcement." Meanwhile, T.M. also appealed the consent order to the Appellate Court of Maryland, raising similar arguments; that state appeal remains stayed.
The US District Court for the District of Maryland dismissed the complaint sua sponte for lack of subject matter jurisdiction under the Rooker-Feldman doctrine, and the Fourth Circuit affirmed. The Court granted certiorari to resolve a conflict among the Courts of Appeals over whether the Rooker-Feldman doctrine applies only to final judgments rendered by the highest court of a State in which a decision could be had, or whether it also bars suits when the state-court judgment remains subject to further review in state appellate proceedings.
The Court reaffirmed that the Rooker-Feldman doctrine is "narrow" and applies only in "limited circumstances." The Court concluded that T.M.'s suit falls within "the narrow ground occupied by Rooker-Feldman" because T.M. "is complaining of injuries caused by, and seeking relief from, the state-court judgment itself," asking a federal district court to declare the consent order "unconstitutional, unenforceable, and void ab initio" and to enjoin its enforcement. The Court rejected T.M.'s argument, endorsed by the dissent, that the Rooker-Feldman doctrine should bar "only federal suits seeking review and rejection of '[f]inal judgments' that are 'rendered by the highest court of a State in which a decision could be had'" under 28 U.S.C. § 1257(a). The Court reasoned that adopting T.M.'s rule "would require the Court to abandon a central part of Rooker's reasoning and reinterpret the doctrine to rest solely on a strict negative inference from § 1257."
The Court further explained that "allowing federal district courts to review state-court judgments while they are on appeal in the state-court system would undermine the '[c]ooperation and comity' on which our federal system is built," and that "[f]ederalism principles are thus best served by continuing to apply Rooker-Feldman to federal cases in which plaintiffs seek review of state-court judgments, regardless of whether those judgments are final trial-court judgments or those of a State's highest court." Ultimately, "[t]he Court today neither expands nor constrains Rooker-Feldman" but instead "leaves the doctrine as it found it: narrowly confined to 'cases brought by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments.'" Because T.M.'s suit "falls within these strict limits," the Court affirmed the judgment of the Fourth Circuit.
Justice Sotomayor delivered the opinion of the court, in which Justices Thomas, Alito, Kavanaugh, and Jackson joined. Justice Thomas filed a concurring opinion. Justice Barrett filed a dissenting opinion, in which Chief Justice Roberts and Justices Kagan and Gorsuch joined.
